Government Contracts Insights

When Does the So-Called TikTok Ban Really Apply to Contractors and Their Employees?

By Morrison Foerster LLP · Jun 22, 2023

In the extensive chatter since the Federal Acquisition Regulatory Council (“FAR Council”) published an interim rule on the new Federal Acquisition Regulation (FAR) 52.204-27, “Prohibition on a ByteDance Covered Application,” commentators have almost universally advised that if a federal contractor’s employee uses a device in connection with a government contract in any way, TikTok is banned on that device.  These conclusions seem to rely on the common understanding of the term “information technology.” 

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