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  • Mason Goodman


Staying informed about regulatory changes is paramount for government contractors to ensure compliance and foster successful partnerships. One such recent development affecting government contractors is the implementation of FAR 52.204-27: Prohibition on a ByteDance Covered Application. This article aims to provide government contractors with a clear understanding of the key provisions of this regulation and practical steps to implement it within their organizations.

Understanding the Prohibition:

FAR 52.204-27 establishes a strict prohibition on the use of TikTok or any similar application developed or provided by ByteDance Limited. This restriction applies to government-owned or managed information technology systems, as well as information technology used by the contractor under the contract. Additionally, it covers equipment provided by the contractor’s employees. The primary objective is to ensure compliance with the No TikTok on Government Devices Act and its implementing guidance.

Exceptions and Recommendations:

While the regulation allows for exceptions, granting them is contingent upon the Contracting Officer’s specific criteria. However, industry practitioners recommend interpreting the regulation in a company-wide manner to ensure comprehensive compliance. Given the broad definition of “information technology” and the increasing integration of systems, adopting a company-wide approach mitigates potential risks and ensures adherence to the policy.

Implementing the Regulation:

To effectively implement FAR 52.204-27 within your company, consider the following practical steps:

1. Update Employee Handbook: Promptly incorporate the TikTok usage restriction into your employee handbook, clearly communicating the prohibition to all employees. This ensures everyone is aware of the policy and can comply with it accordingly.

2. Informative Communication: Issue a company-wide email that provides detailed information about the new rule, its implications, and the underlying reasons. Transparent communication fosters understanding and promotes cooperation among employees.

3. Training and Education: Conduct comprehensive training sessions to familiarize employees with the regulation, including its implications, compliance best practices, and potential consequences of non-compliance. These sessions will help employees understand their responsibilities and reinforce the importance of compliance.

4. Technological Measures: Explore technological solutions to restrict the download and usage of TikTok on company-owned equipment. Implement robust controls, such as firewalls or access management systems, to enforce compliance and minimize the risk of unauthorized usage.

Understanding and implementing FAR 52.204-27 is essential for government contractors to ensure compliance with regulatory requirements. By promptly updating the employee handbook, communicating the policy changes effectively, conducting comprehensive training sessions, and leveraging technology for enforcement, clients can seamlessly achieve compliance throughout their organizations. Compliance not only fulfills legal obligations but also safeguards sensitive information and maintains the trust of government partners.

For more information regarding FAR 52.204-27 compliance and to find out whether you are subject to the requirements of FAR 52.204-27, please contact Mason Goodman at Fonss & Estigarribia LLP at and (858) 746-6497.

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