Breaking Down Section 889, The Biggest Compliance Change for Federal Contractors – Megan Brown

August 11, 2020
Harris Allgeier

Episode 10: Breaking Down Section 889, The Biggest Compliance Change for Federal Contractors w/ Megan Brown


“I think the broader economy had no real insight into this evolving mindset of the US government on these Chinese technology companies.” –  Megan Brown

August 13 is approaching and, for many in the Defense Industrial base (and beyond) that means it’s time for another regulatory complication to global trade, specifically the implementation of Section 889, which forbids the government from contracting with companies who have telecom and surveillance equipment from 5 major chinese companies in their supply chains, including Huawei and ZTE.

But what, exactly does that mean? And how can businesses get ahead of this massive regulatory effort?

Thankfully there are people like Megan Brown in the world. Megan is an attorney and partner at Wiley Rein LLP, and on this episode of What Lies Beneath?, our guest host, Andrea Little Limbago, talks to Megan all about: 

  • The role of bias and how it fits into regulations and insecurity
  • The 2 parts of Section 889 (sections A & B) and what they have to do with the global supply chain
  • Why the US government is so set on not doing business with companies like Huawei
  • Why the lack of definitions in the statute and the lack of clarity could make things more complicated for compliance

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To learn more about how Interos can help you with Section 889 Part B compliance, visit



Andrea Little Limbago: 

Dr. Andrea Little Limbago is a computational social scientist specializing in the intersection of technology, national security, and society. As the Vice President of Research and Analysis at Interos, Andrea leads the company’s research and analytic work regarding global supply chain risk with a focus on governance, cyber, economic, and geopolitical factors. She also oversees community engagement and research partnerships with universities and think tanks and is a frequent contributor to program committees and mentorship and career coaching programs. She has presented extensively at a range of academic, government, and industry conferences such as RSA, SOCOM’s Global Synch, BSidesLV, SXSW, and Enigma. Her writing has been featured in numerous outlets, including Politico, the Hill, Business Insider, War on the Rocks, and Forbes. Andrea is also a Senior Fellow and Program Director for the Cyber and Emerging Technologies Law and Policy Program at the National Security Institute at George Mason and a Fellow at the Atlantic Council’s GeoTech Center. She is an industry advisory board member for the data science program at George Washington University, and is a board member for the Washington, DC chapter of Women in Security and Privacy (WISP). She previously was the Chief Social Scientist at Virtru and Endgame. Prior to that, Andrea taught in academia and was a technical lead at the Joint Warfare Analysis Center, where she earned the Command’s top award for technical excellence. Andrea earned a PhD in Political Science from the University of Colorado at Boulder and a BA from Bowdoin College


Megan Brown:  Megan represents corporations in complex proceedings concerning technological innovation and regulation. She helps clients respond to agency and Congressional inquiries and develop compliance strategies under a variety of statutes, including the Federal Trade Commission Act, the Federal Communications Act, and state consumer protection and cybersecurity laws. Megan has deep expertise in cybersecurity and data privacy issues, working for national and global companies on cutting edge compliance and risk management.

As a former senior Department of Justice official in the George W. Bush administration, Megan helps clients navigate the current administration. She also serves on the U.S. Chamber of Commerce’s Cybersecurity Leadership Council and is Associate Director for Cybersecurity at George Mason law school’s National Security Institute.

Megan is a contributing author and an industry source in several publications, including the “Cybersecurity Risk Management Is a Corporate Responsibility” chapter in the American Bar Association’s 2019 publication, The Lawyer’s Corporate Social Responsibility Deskbook.

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