.compliance/SECTION_889_REP.md

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# Section 889 Representation — FAR 52.204-25

**Repository:** `szl-holdings/a11oy`
**Entity:** SZL Holdings
**Date:** 2026-06-01

This representation accompanies the SZL Holdings governed agentic mesh
(Doctrine v11 LOCKED 749/14/163, sovereign-default). It implements the
prohibition of FY2019 NDAA §889 as set out in FAR 52.204-25.

---

## FAR 52.204-25 — Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services or Equipment (verbatim representation text)

> **(a) Definitions.** As used in this clause —
>
> *Backhaul, covered telecommunications equipment or services, critical
> technology, interconnection arrangements, reasonable inquiry, roaming, and
> substantial or essential component* have the meanings provided in the clause
> 52.204-25, Prohibition on Contracting for Certain Telecommunications and Video
> Surveillance Services or Equipment.
>
> **(b) Prohibition.**
> (1) Section 889(a)(1)(A) of the John S. McCain National Defense Authorization
> Act for Fiscal Year 2019 (Pub. L. 115-232) prohibits the head of an executive
> agency on or after August 13, 2019, from procuring or obtaining, or extending
> or renewing a contract to procure or obtain, any equipment, system, or service
> that uses covered telecommunications equipment or services as a substantial or
> essential component of any system, or as critical technology as part of any
> system. The Contractor is prohibited from providing to the Government any
> equipment, system, or service that uses covered telecommunications equipment or
> services as a substantial or essential component of any system, or as critical
> technology as part of any system, unless an exception at paragraph (c) of this
> clause applies or the covered telecommunication equipment or services are
> covered by a waiver described in FAR 4.2104.
>
> (2) Section 889(a)(1)(B) of the John S. McCain National Defense Authorization
> Act for Fiscal Year 2019 (Pub. L. 115-232) prohibits the head of an executive
> agency on or after August 13, 2020, from entering into a contract, or extending
> or renewing a contract, with an entity that uses any equipment, system, or
> service that uses covered telecommunications equipment or services as a
> substantial or essential component of any system, or as critical technology as
> part of any system, unless an exception at paragraph (c) of this clause applies
> or the covered telecommunication equipment or services are covered by a waiver
> described in FAR 4.2104. This prohibition applies to the use of covered
> telecommunications equipment or services, regardless of whether that use is in
> performance of work under a Federal contract.

---

## Representation (FAR 52.204-26 / SAM.gov)

**SZL Holdings does NOT provide or use covered telecommunications equipment or
services from: Huawei, ZTE, Hytera, Hikvision, Dahua, or their subsidiaries or
affiliates** — as a substantial or essential component of any system, or as
critical technology as part of any system.

- The agentic mesh runs on mainstream commercial cloud / CNCF-certified
  Kubernetes (k3s/RKE2) and air-gapped single-node hardware. None of the
  build, runtime, or development bench incorporates covered equipment.
- No Huawei/ZTE telecommunications gear; no Hikvision/Dahua video-surveillance
  equipment; no Hytera radios are used as components.
- Per FAR, any covered item discovered during performance will be reported to
  the contracting officer within **one (1) business day**.

---

## Attestation

Signed by:

**Stephen P. Lutar Jr.**
Founder, SZL Holdings
ORCID 0009-0001-0110-4173
Date: **2026-06-01**

_Signature on file (DCO-signed commit; founder e-signature to be applied at award
per FAR 52.204-25 representation procedure)._

---

<sub>Doctrine v11 LOCKED 749/14/163 · Λ Conjecture 1 · sovereign-default. Cosign fingerprint
`b066de4081a3a49dd98d830ee68938facb86ffa5a658e71ddfe27b00b00f5dd2`.</sub>