This attestation covers Formation Ads's own systems, technology stack, hosting providers, and service integrations.
Scope Limitation
This Section 889 compliance attestation applies exclusively to Formation Ads's own infrastructure and systems. It does not extend to Meta Platforms, Inc. or any third-party advertising platform. Organizations must independently assess Meta's compliance status as part of their own procurement due diligence.
Overview
Section 889 of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (Public Law 115-232) prohibits the federal government from procuring or contracting with entities that use covered telecommunications equipment or services. The Federal Acquisition Regulation (FAR) implements this prohibition at 48 CFR 52.204-25.
Formation Ads is designed from the ground up to support organizations that operate under government contracting requirements, including full compliance with Section 889.
Our Compliance Commitments
No Covered Equipment
Our platform does not use any telecommunications or video surveillance equipment from covered entities in any component of our infrastructure.
Supply Chain Verification
All third-party service providers — Meta, Stripe, Cloudflare, Sentry, Vercel — are US-headquartered companies. Based on publicly available information and provider representations, we are not aware of any covered telecommunications dependencies.
Continuous Monitoring
We continuously monitor our technology stack and service provider relationships. If any change affects our compliance posture, we notify affected organizations immediately.
Annual Attestation
We produce annual compliance attestation documents and maintain an immutable audit trail of all platform actions for government inspection.
US-Based Infrastructure
All Formation Ads infrastructure operates from United States data centers provided by US-headquartered companies:
- Application hosting: Vercel (serverless, US regions)
- Database: PostgreSQL via Vercel (US data centers)
- Object storage: Cloudflare R2 (US-headquartered, S3-compatible)
- Error monitoring: Sentry (US-headquartered)
- Payment processing: Stripe (US-headquartered, PCI DSS Level 1)
Prohibited Entities
Section 889 applies to telecommunications equipment and services from the following entities and their subsidiaries or affiliates:
- Huawei Technologies Company(and subsidiaries/affiliates)
- ZTE Corporation(and subsidiaries/affiliates)
- Hytera Communications Corporation(and subsidiaries/affiliates)
- Hangzhou Hikvision Digital Technology Company(and subsidiaries/affiliates)
- Dahua Technology Company(and subsidiaries/affiliates)
Also includes any entity the Secretary of Defense determines is owned or controlled by the government of a covered foreign country.
Formation Ads does not use products, services, or components from any of these entities or their subsidiaries in any part of our infrastructure.
Regulatory References
| Reference | Description |
|---|---|
| FAR 52.204-24 | Representation Regarding Certain Telecommunications and Video Surveillance Services or Equipment |
| FAR 52.204-25 | Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services or Equipment |
| Section 889, NDAA FY2019 | John S. McCain National Defense Authorization Act for Fiscal Year 2019 (Public Law 115-232), Section 889 |
Generating Your Attestation
Organizations using Formation Ads can generate a formal Section 889 compliance attestation document through the platform dashboard. This attestation:
- Includes specific declarations of compliance tailored to your organization.
- Can be digitally signed by an authorized representative within your organization.
- Is available as a print-ready document suitable for inclusion in government contract submissions.
- Is recorded in the platform's immutable audit log with generation timestamp and signatory information.
Disclaimer
Formation Ads provides compliance tooling and attestation generation to assist organizations with their FAR 52.204-25 obligations. This does not constitute legal advice. Each organization is responsible for independently verifying its compliance with applicable regulations and contract requirements.
Compliance Verification
Compliance Team
For compliance questions, verification requests, or to report a concern, contact us at compliance@formationads.com.
We respond to all compliance inquiries within 2 business days.