HomeMy WebLinkAboutGrantDHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
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AGREEMENT FACE SHEET
FY 2026 FIFA World Cup Grant Program (FY 2026 FWCGP)
1.Subrecipient Name and Address:
Renton Police Department
1055 S. Grady Way
Renton, WA 98057
2.Grant Agreement Amount:
378,412.00
3.Grant Agreement Number:
FWCGP-15
4. Subrecipient Contact,
phone/email:
Ryan Rutledge
425-430-7512
rrutledge@rentonwa.gov
5.Grant Agreement Start Date:
July 4, 2025
6.Grant Agreement End
Date:
August 31, 2026
7. Organization Contact,
phone/email:
Casey Broom, 360-202-3001,
caseyb@sea2026.org
8.Unique Entity Identifier (UEI) :
UG2PSBS6UJJ3
9. UBI (state revenue):
177-000-094
10.Funding Authority:
Washington Military Department (the Department) and the U.S. Department of Homeland
Security (DHS)
11.Federal Funding ID #:
EMW-2026-WC-05005
12.Federal Award Date:
03/18/2026
13.Assistance Listings &
Title:
97.160 - FY 2026 FWCGP
14.Total Federal Award Amount:
32,252,845
15.Contract Type (check all that
apply):
Contract Grant
Agreement
Intergovernmental (RCW 39.34)
Interagency
16.Subrecipient Type (check
all that apply):
Private
Organization/Individual
For-Profit Public
Organization/Jurisdiction
non-profit
CONTRACTOR
SUBRECIPIENT
OTHER
17.PURPOSE & DESCRIPTION:
The objective of the Federal Fiscal Year (FFY) 2026 FIFA World Cup (FY 2026 FWCGP) grant
program is to provide targeted funding to enhance security and preparedness for the 2026 FIFA
World Cup events hosted in the United States. It will provide Federal resources to help Host Cities in
implementing the necessary security measures and strengthen capabilities required for this series of
high-risk events. FWC grant funds will enhance the ability of local law enforcement, emergency
responders, and public safety officials to prepare for, protect against, and respond to threats and
emergencies during the World Cup matches.
The Organization is a sub-recipient and Pass-through Entity of the FY 2026 FWCGPC Award Letter
for Grant No. EMW-2026-W-05005 ("the Grant"), which is incorporated in and attached hereto as
Attachment C, and has made a subaward of Federal award funds to the Subrecipient pursuant to
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this Agreement. The Subrecipient is accountable to the Organization for use of Federal award funds
provided under this Agreement.
IN WITNESS WHEREOF, the Organization and Subrecipient acknowledge and accept the terms of this
Agreement, including all referenced attachments which are hereby incorporated, and have executed this
Agreement as of the date below. This Agreement Face Sheet; Special Terms & Conditions (Attachment A);
General Terms and Conditions (Attachment B); DHS Award Letter EMW-026-W-05005 (Attachment C); Work
Plan, (Attachment D); Timeline (Attachment E); Budget (Attachment F); Build America, Buy America Act Self-
Certification (Attachment G), and all other documents and attachments expressly referenced and
incorporated herein contain all the terms and conditions agreed upon by the parties and govern the rights
and obligations of the parties to this Agreement. No other understandings, oral or otherwise, regarding the
subject matter of this Agreement shall be deemed to exist or to bind any of the parties.
In the event of an inconsistency among the provisions of the above-described Attachments, unless otherwise
provided herein, the inconsistency shall be resolved by giving precedence in the following order:
1. Applicable Federal and State Statutes and Regulations
2.DHS/FEMA Award and program documents
3.Work Plan, Timeline, and Budget
4. Special Terms and Conditions
5.General Terms and Conditions
6.Other provisions of the Agreement incorporated by reference
WHEREAS, the parties have executed this Agreement on the day, and year last specified below.
FOR THE ORGANIZATION: FOR THE SUBRECIPIENT:
Signature Date
Ann Kawasaki Romero
SeattleFWC26
BOILERPLATE APPROVED TO FORM:
5/08/2026
Signature Date
Armondo Pavone, Mayor
City of Renton
APPROVED AS TO FORM (if applicable):
Signature Date
6/2/2026
Approved by Alex Tuttle via memo 5/28/2026
Attest:___________________________________
Jason Seth, City Clerk
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ATTACHMENT A
SPECIAL TERMS AND CONDITIONS
FY 2026 FIFA World Cup Grant Program
ARTICLE I. KEY PERSONNEL
The individuals listed below shall be considered key personnel for point of contact under this Agreement. Any
substitution for key personnel by either party shall be made by written notification to the current key
personnel.
SUBRECIPIENT ORGANIZATION
Name Ryan Rutledge Name Casey Broom
Title Deputy Chief of Police Title VP, Security
Email RRutledge@rentonwa.gov Email Caseyb@sea2026.org
Phone 425-430-7512 Phone 360-202-3001
Name Name George Dugdale
Title Title SVP Business Operations
Email Email georged@sea2026.org
Phone Phone 206-390-2012
ARTICLE II. ADMINISTRATIVE AND/OR FINANCIAL REQUIREMENTS
The Subrecipient shall comply with all applicable state and federal laws, rules, regulations, requirements and
program guidance identified or referenced in this Agreement and the informational documents published by
DHS/FEMA applicable to the FY 2026 FWCGP grant program, including, but not limited to, all criteria,
restrictions, and requirements of "The Department of Homeland Security (DHS) Notice of Funding
Opportunity (NOFO) Fiscal Year 2026 FIFA World Cup Grant Program" (hereafter "the NOFO"), the
Preparedness Grants Manual FM 207-23-0001 August 2025 (hereafter "the Manual"), the DHS Award Letter
for the Grant, and the federal regulations commonly applicable to DHS/FEMA grants, all of which are
incorporated herein by reference. The DHS Award Letter is incorporated in this Agreement as Attachment C.
The Subrecipient acknowledges that since this Agreement involves federal award funding, the period of
performance may begin prior to the availability of appropriated federal funds. The Subrecipient agrees that it
will not hold the Organization, the state of Washington, or the United States liable for any damages, claim for
reimbursement, or any type of payment whatsoever for services performed under this Agreement prior to
distribution of appropriated federal funds.
A. STATE AND FEDERAL REQUIREMENTS FOR DHS/FEMA PREPAREDNESS GRANTS
The following requirements apply to all DHS/FEMA Preparedness Grants.
1. SUBAWARDS & CONTRACTS BY SUBRECIPIENTS
a. The Subrecipient must make a case-by-case determination whether each agreement it makes for the
disbursement of FY 2026 FWCGP funds received under this Agreement casts the party receiving the funds
in the role of a subrecipient or contractor in accordance with 2 CFR 200.331.
b. If the Subrecipient becomes a pass-through entity by making a subaward to a subrecipient:
i. The Subrecipient must comply with all federal laws and regulations applicable to pass-through
entities of FY 2026 FWCGP funds, including, but not limited to, those contained in 2 CFR 200.
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ii. The Subrecipient shall require its subrecipient(s) to comply with all applicable state and federal
laws, rules, regulations, requirements and program guidance identified or referenced in this
Agreement and the informational documents published by DHS/FEMA applicable to the FY 2026
FWCGP grant program, including, but not limited to, all criteria, restrictions, and requirements of the
NOFO, the Manual, the Grant, and the federal regulations commonly applicable to DHS/FEMA
grants.
iii. The Subrecipient shall be responsible to the Organization for ensuring that all FY 2026 FWCGP
federal award funds provided to its subrecipients are used in accordance with applicable federal and
state statutes and regulations, and the terms and conditions of the federal award set forth in this
Agreement.
iv. The Subrecipient must follow their own policies and procedures to eliminate or reduce the impact
of conflicts of interest when making subawards, adhering to any applicable federal or state statutes
or regulations. Any real or potential conflicts of interest must be reported to the Organization in
writing upon discovery.
2. BUDGET, REIMBURSEMENT, AND TIMELINE
a. Within the total Grant Agreement Amount, travel, subcontracts, salaries, benefits, printing, equipment, and
other goods and services or other budget categories will be reimbursed on an actual cost basis upon
completion unless otherwise provided in this Agreement.
b. The maximum amount of all reimbursement requests permitted to be submitted under this Agreement,
including the final reimbursement request, is limited to and shall not exceed the total Grant Agreement
Amount.
c. If the Subrecipient chooses to include indirect costs within the Budget (Attachment F), additional
documentation is required based on the applicable situation, as described in 2 CFR 200.414 and Appendix
VII to 2 CFR 200:
i. If the Subrecipient receives direct funding from any Federal agency(ies): (A) More than $35 million,
the approved indirect cost rate agreement negotiated with its federal cognizant agency; (B) Less
than $35 million, the indirect cost proposal developed in accordance with Appendix VII of 2 CFR 200
requirements.
ii. If the Subrecipient does not receive direct federal funds (i.e., only receives funds as a
subrecipient), the Subrecipient must either elect to charge a de minimis rate of fifteen percent (15%)
of modified total direct costs or choose to negotiate a higher rate with the Organization.
iii. Indirect costs must be expressly identified in the Budget using a single, consistent methodology and
shall not be adjusted or modified without prior written approval from the Organization.
d. For travel costs, the Subrecipient shall comply with 2 CFR 200.475 and should consult their internal
policies, state rates set pursuant to RCW 43.03.050 and RCW 43.03.060, and federal maximum rates set
forth at https://www.gsa.gov, and follow the most restrictive. All international travel requires prior FEMA
approval.
e. Reimbursement requests will include a properly completed Reimbursement Spreadsheet detailing the
expenditures for which reimbursement is sought. Reimbursement requests must be submitted to
FWCGP@sea2026.org no later than the due dates listed within the Timeline (Attachment E).
f. Receipts and/or backup documentation for any approved items must be maintained by the Subrecipient
consistent with record retention requirements and be made available upon request.
g. The Subrecipient must request prior written approval from Organization Key Personnel to waive or extend
a due date in the Timeline (Attachment E).
h. All work under this Agreement must end on or before the Grant Agreement End Date, and the final
reimbursement request must be submitted before the date notated in the Timeline (Attachment E).
i. All costs for equipment and supplies must be incurred, and items received before the Grant Agreement
End Date.
j. Failure to submit timely, accurate, and complete reports and reimbursement requests will prohibit the
Subrecipient from being reimbursed until such reports are submitted and reviewed.
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k. Final reimbursement requests will not be approved for payment until the Subrecipient is current with all
reporting requirements.
l. A written amendment will be required if the Subrecipient expects cumulative transfers among solution area
totals to exceed ten percent (10%) of the Grant Agreement Amount.
m. Subrecipients shall only use federal award funds under this Agreement to supplement existing funds and
will not use them to replace (supplant) non-federal funds.
3. REPORTING REQUIREMENTS
a. With each reimbursement request, the Subrecipient shall report how the expenditures relate to the Work
Plan (Attachment D) activities in the format provided by the Organization.
b. With the final reimbursement request, the Subrecipient shall submit a final report to
FWCGP@sea2026.org describing all completed activities under this Agreement.
c. The Subrecipient shall comply with the Federal Funding Accountability and Transparency Act (FFATA)
and related OMB Guidance consistent with Public Law 109-282 as amended and complete and return to the
Organization an Audit Certification/FFATA Form.
4. EQUIPMENT AND SUPPLY MANAGEMENT
a. The Subrecipient and any subrecipient to which the Subrecipient makes a subaward shall comply with 2
CFR 200.317 through 200.327, and all Washington State procurement statutes, when procuring any
equipment or supplies under this Agreement.
b. All equipment and supplies purchased through this Agreement will be recorded and maintained in the
Subrecipient's inventory system. Inventory records shall include: description, serial/model number, Federal
Award Identification Number (FAIN), Assistance Listings Number, title holder, acquisition date, cost and
federal participation percentage, location/use/condition, and disposition data.
c. The Subrecipient shall take a physical inventory of equipment and reconcile with property records at least
once every two years.
d. Records for equipment shall be retained for a period of six (6) years from the date of the disposition,
replacement, or transfer.
e. Effective August 13, 2020, FEMA recipients and subrecipients may not obligate or expend any FEMA
award funds to procure equipment, systems, or services that use covered telecommunications equipment or
services as defined in section 889 of the John S. McCain National Defense Authorization Act for Fiscal Year
2019 (FY 2019 NDAA), Pub. L. No. 115-232 (2018). Covered entities include Huawei Technologies
Company, ZTE Corporation, Hytera Communications Corporation, Hangzhou Hikvision Digital Technology
Company, and Dahua Technology Company, or any subsidiary or affiliate of such entities.
5. ENVIRONMENTAL AND HISTORICAL PRESERVATION
a. The Subrecipient shall ensure full compliance with the DHS/FEMA Environmental Planning and Historic
Preservation (EHP) Program. EHP program information can be found at
https://www.fema.gov/grants/guidance-tools/environmental-historic.
b. Projects that have historical impacts or the potential to impact the natural or built environment must
participate in the DHS/FEMA EHP review process prior to project initiation. The EHP review process must be
completed, and FEMA approval must be received by the Subrecipient before any work is started for which
reimbursement will be later requested.
6. PROCUREMENT
The Subrecipient shall comply with all procurement requirements of 2 CFR 200.317 through 200.327.
a. For all contracts expected to exceed the simplified acquisition threshold, the Subrecipient must notify the
Organization. The Organization may request pre-procurement documents such as requests for proposals,
invitations for bids, and independent cost estimates.
b. For all sole source contracts expected to exceed the micro-purchase threshold per 2 CFR 200.1, the
Subrecipient must submit justification to the Organization
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c. The Subrecipient as well as its contractors and subcontractors must comply with the Build America, Buy
America Act (BABAA), which was enacted as a part of the Infrastructure Investment and Jobs Act §§ 70901-
70297, Pub. L. No. 117-58 (2021), requiring that infrastructure projects use iron, steel, and manufactured
products produced in the United States. The Build America, Buy America Act Self-Certification form is
included herein as Attachment G.
7. SUBRECIPIENT MONITORING
a. The Organization will monitor the activities of the Subrecipient from award to closeout. The goal of the
Organizations monitoring activities will be to ensure that subrecipients receiving federal pass-through funds
are in compliance with this Agreement, federal and state audit requirements, federal grant guidance, and
applicable federal and state financial regulations, as well as 2 CFR Part 200 Subpart F.
b. Monitoring activities may include but are not limited to: review of financial and performance reports;
monitoring and documenting completion of Agreement deliverables; documentation of phone calls, meetings,
emails and correspondence; review of reimbursement requests; observation of Agreement-related activities
such as exercises, training, events, and equipment demonstrations; and on-site visits to review equipment
records and inventories.
8. LIMITED ENGLISH PROFICIENCY (CIVIL RIGHTS ACT OF 1964 TITLE VI)
a. The Subrecipient must comply with the Title VI of the Civil Rights Act of 1964 prohibition against
discrimination on the basis of national origin, which requires that subrecipients of federal financial assistance
take reasonable steps to provide meaningful access to persons with limited English proficiency (LEP) to their
programs and services.
b. Subrecipients are encouraged to perform and document their analysis of the most appropriate language
assistance services. The analysis should consider: the number or proportion of LEP individuals eligible to be
served; the frequency with which LEP individuals come in contact with the program; the nature and
importance of the program to people's lives; and the resources available to the program and costs.
B. FWC SPECIFIC REQUIREMENTS
The objectives of the FWC are to enhance security and preparedness for the 2026 FIFA World Cup events in
the United States.
1. The Subrecipient shall use the federal funds authorized under this Agreement only to perform tasks as
described in the Work Plan (Attachment D) and the Subrecipient's approved application for funding,
incorporated into this Agreement.
2. Funding may not be used to replace or supplant non-federal funding of emergency management
programs.
3. The Subrecipient shall report on the following performance measures and targets per the NOFO:
x Number of FWCGP-funded operational overtime hours tracked and reported by the
recipient in support of security and public safety operations for FIFA World Cup-related
planning and event execution.
x Number of DHS/FEMA-sponsored and approved Training Sessions completed for law
enforcement, emergency responders, and security personnel using FWCGP funds.
x Number of Homeland Security Exercise and Evaluation Program (HSEEP)-compliant
Exercises completed for law enforcement, emergency responders, and security personnel
using FWCGP funds.
x Number of FWCGP-funded Emergency Response Teams deployed to FIFA venues,
hotels, and transportation hubs.
x The number of security incidents successfully managed or mitigated during the World
Cup events.
x Collect feedback from international visitors, FIFA officials, and local stakeholders on the
overall security and preparedness of the events.
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C. DHS TERMS AND CONDITIONS
As a Subrecipient of FY 2026 FWCGP funding, the Subrecipient shall comply with all applicable DHS terms
and conditions of the Award Letter and its incorporated documents for the Grant, which are incorporated and
made a part of this Agreement as Attachment C.
ATTACHMENT B
GENERAL TERMS AND CONDITIONS
SeattleFWC26 | DHS/FEMA Grants
Department of Homeland Security (DHS) / Federal Emergency Management Agency (FEMA)
1. DEFINITIONS
As used throughout this Agreement, the terms will have the same meaning as defined in 2 CFR 200 Subpart
A (which is incorporated herein by reference), except as otherwise set forth below:
a. "Agreement" means this Grant Agreement.
b. "Organization" means SeattleFWC26, a private not for profit organization that serves as the Local
Organizing Committee hosting and staging the FIFA World Cup 2026 games in Seattle, Washington, or any
of the officers or other officials lawfully representing that Organization. The Organization is a sub-recipient of
a federal award from a federal awarding agency and is the pass-through entity making a subaward to a
Subrecipient under this Agreement.
c. "Monitoring Activities" means all administrative, financial, or other review activities that are conducted to
ensure compliance with all state and federal laws, rules, regulations, authorities and policies.
d. "Subrecipient" when capitalized is primarily used throughout this Agreement in reference to the non-
federal entity identified on the Face Sheet of this Agreement that has received a subaward from the
Organization.
2. ADVANCE PAYMENTS PROHIBITED
The Organization shall make no payments in advance or in anticipation of goods or services to be provided
under this Agreement. The Subrecipient shall not invoice the Organization in advance of delivery and
invoicing of such goods or services.
3. AMENDMENTS AND MODIFICATIONS
The Subrecipient or the Organization may request, in writing, an amendment or modification of this
Agreement. However, such amendment or modification shall not be binding, take effect or be incorporated
herein until made in writing and signed by the authorized representatives of the Organization and the
Subrecipient. No other understandings or agreements, written or oral, shall be binding on the parties.
The Agreement performance period shall only be extended by (1) written notification of DHS/FEMA approval
of the Award performance period, followed up with a mutually agreed written amendment, or (2) written
notification from the Organization to the Subrecipient to provide additional time for completion of the
Subrecipient's project(s).
4. AMERICANS WITH DISABILITIES ACT (ADA) OF 1990
Except as provided herein, the Subrecipient must comply with the ADA (Public Law 101-336, 42 U.S.C.
12101 et seq., 28 CFR Part 35), which provides comprehensive civil rights protection to individuals with
disabilities in the areas of employment, public accommodations, state and local government services, and
telecommunication.
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5. ASSURANCES
The Organization and Subrecipient agree that all activity pursuant to this Agreement will be in accordance
with all the applicable current federal, state and local laws, rules, and regulations.
6. CERTIFICATION REGARDING DEBARMENT, SUSPENSION, OR INELIGIBILITY
As federal funds are a basis for this Agreement, the Subrecipient certifies that the Subrecipient is not
presently debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from
participating in this Agreement by any federal department or agency. The Subrecipient shall complete, sign,
and return a Certification Regarding Debarment, Suspension, Ineligibility, and Voluntary Exclusion form. The
Subrecipient certifies that it will ensure that potential contractors or subrecipients or any of their principals are
not debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from
participation in "covered transactions" by any federal department or agency.
7. CERTIFICATION REGARDING RESTRICTIONS ON LOBBYING
As required by 44 CFR Part 18, the Subrecipient hereby certifies that to the best of its knowledge and belief:
1) no federally appropriated funds have been paid or will be paid to any person for influencing or attempting
to influence an officer or employee of an agency, a Member of Congress, or an employee of a Member of
Congress in connection with the awarding of any federal contract or the making of any federal grant; (2) if
any funds other than federal appropriated funds have been paid to any person for influencing activities, the
Subrecipient will complete and submit Standard Form-LLL; and (3) the Subrecipient will require the language
of this certification be included in the award documents for all subawards at all tiers.
8. COMPLIANCE WITH APPLICABLE STATUTES, RULES AND DEPARTMENT POLICIES
The Subrecipient and all its contractors and subrecipients shall comply with, and the Organization is not
responsible for determining compliance with, any and all applicable federal, state, and local laws,
regulations, executive orders, OMB Circulars, and/or policies. This obligation includes, but is not limited to:
nondiscrimination laws, Energy Policy and Conservation Act, the ADA, Age Discrimination Act of 1975, Title
VI of the Civil Rights Act of 1964, Civil Rights Act of 1968, the Robert T. Stafford Disaster Relief and
Emergency Assistance Act, Ethics in Public Service (RCW 42.52), Public Records Act (RCW 42.56),
Prevailing Wages on Public Works (RCW 39.12), State Environmental Policy Act (RCW 43.21C), and safety
and health regulations.
9. CONFLICT OF INTEREST
No officer or employee of the Organization; no member, officer, or employee of the Subrecipient or its
designees or agents; no member of the governing body of the jurisdiction in which the project is undertaken
or located; and no other official of the Subrecipient who exercises any functions or responsibilities with
respect to the project during his or her tenure, shall have any personal or pecuniary gain or interest, direct or
indirect, in any contract, subcontract, or the proceeds thereof, for work to be performed in connection with
the project assisted under this Agreement.
10. CONTRACTING & PROCUREMENT
a. The Subrecipient shall use a competitive procurement process in the procurement and award of any
contracts with contractors or subcontractors in accordance with 2 CFR Part 200.318 through 200.327.
All contracts entered into by the Subrecipient must include the following provisions, as applicable:
administrative/contractual/legal remedies for contracts over the simplified acquisition threshold ($250,000);
termination for cause and for convenience for contracts in excess of $10,000; Equal Employment
Opportunity; Davis-Bacon Act compliance where required; Contract Work Hours and Safety Standards Act
compliance; Rights to Inventions; Clean Air Act and Federal Water Pollution Control Act compliance for
amounts over $150,000; Debarment and Suspension; Byrd Anti-Lobbying Amendment; Procurement of
recovered materials; access to records; retention of required records for six years; and energy efficiency
standards.
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b. The Organization reserves the right to review the Subrecipient's procurement plans and documents and
require the Subrecipient to make changes to bring its plans and documents into compliance with 2 CFR Part
200.317 through 200.327.
c. All contracting agreements entered into pursuant to this Agreement shall incorporate this Agreement by
reference.
11. DISCLOSURE
The use or disclosure by any party of any information concerning the Organization for any purpose not
directly connected with the administration of the Organization's or the Subrecipient's responsibilities with
respect to services provided under this Agreement is prohibited except by prior written consent of the
Organization or as required to comply with the state Public Records Act, other law or court order.
12. DISPUTES
Except as otherwise provided in this Agreement, when a bona fide dispute arises between the parties and it
cannot be resolved through discussion and negotiation over a 30-day period, either party may request a
dispute resolution board to resolve the dispute. The board shall consist of a representative appointed by the
Organization, a representative appointed by the Subrecipient, and a third party mutually agreed upon by both
parties. The determination of the dispute resolution board shall be final and binding on the parties. The laws
of the state of Washington and all applicable federal laws shall apply to all disputes hereunder. The venue to
resolve all such disputes shall be Seattle, Washington.
13. LEGAL RELATIONS
It is understood and agreed that this Agreement is solely for the benefit of the parties to the Agreement and
gives no right to any other party. No joint venture or partnership is formed as a result of this Agreement.
To the extent allowed by law, the Subrecipient, its successors or assigns, will protect, save and hold
harmless the Organization, the state of Washington, and the United States Government and their authorized
agents and employees, from all claims, actions, costs, damages or expenses of any nature whatsoever by
reason of the acts or omissions of the Subrecipient, its subcontractors, subrecipients, assigns, agents,
contractors, consultants, licensees, invitees, employees or any person whomsoever arising out of or in
connection with any acts or activities authorized by this Agreement.
44 CFR 206.9 Non-liability: The Federal government shall not be liable for any claim based upon the
exercise or performance of, or the failure to exercise or perform a discretionary function or duty on the part of
a federal agency or an employee of the Federal government in carrying out the provisions of the Stafford Act.
14. LIMITATION OF AUTHORITY – AUTHORIZED SIGNATURE
The signatories to this Agreement represent that they have the authority to bind their respective
organizations to this Agreement. Only the Organization's Authorized Signature representative and the
Authorized Signature representative of the Subrecipient shall have the express, implied, or apparent
authority to alter, amend, modify, or waive any clause or condition of this Agreement.
15. LOSS OR REDUCTION OF FUNDING
In the event funding from state, federal, or other sources is withdrawn, reduced, or limited in any way after
the effective date of this Agreement and prior to normal completion or end date, the Organization may
unilaterally reduce the work plan and budget or unilaterally terminate all or part of the Agreement as a
Termination for Cause" without providing the Subrecipient an opportunity to cure.
16. NONASSIGNABILITY
Neither this Agreement, nor any claim arising under this Agreement, shall be transferred or assigned by the
Subrecipient.
17. NONDISCRIMINATION
During the performance of this agreement, the Subrecipient shall comply with all federal and state
nondiscrimination statutes and regulations. The Subrecipient shall not discriminate against any employee or
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applicant for employment because of race, color, sex, sexual orientation, religion, national origin, creed,
marital status, age, Vietnam era or disabled veteran status, or the presence of any sensory, mental, or
physical handicap.
18. NOTICES
The Subrecipient shall comply with all public notices or notices to individuals required by applicable local,
state and federal laws and regulations and shall maintain a record of this compliance.
19. OCCUPATIONAL SAFETY/HEALTH ACT AND WASHINGTON INDUSTRIAL
SAFETY/HEALTH ACT (OSHA/WISHA)
The Subrecipient represents and warrants that its workplace does now or will meet all applicable federal and
state safety and health regulations that are in effect during the Subrecipient's performance under this
Agreement.
20. OWNERSHIP OF PROJECT/CAPITAL FACILITIES
The Organization makes no claim to any capital facilities or real property improved or constructed with funds
under this Agreement, and by this subaward of funds does not and will not acquire any ownership interest or
title to such property of the Subrecipient. The Subrecipient shall assume all liabilities and responsibilities
arising from the ownership and operation of the project.
21. POLITICAL ACTIVITY
No portion of the funds provided herein shall be used for any partisan political activity or to further the
election or defeat of any candidate for public office or influence the approval or defeat of any ballot issue.
22. PROHIBITION AGAINST PAYMENT OF BONUS OR COMMISSION
The assistance provided under this Agreement shall not be used in payment of any bonus or commission for
the purpose of obtaining approval of the application for such assistance or any other approval or concurrence
under this Agreement.
23. PUBLICITY
The Subrecipient agrees to submit to the Organization prior to issuance all advertising and publicity matters
relating to this Agreement wherein the Organization's name is mentioned or implied. The Subrecipient may
copyright original work it develops in the course of or under this Agreement; however, pursuant to 2 CFR
Part 200.315, FEMA reserves a royalty-free, nonexclusive, and irrevocable license to reproduce, publish or
otherwise use, and to authorize others to use the work for government purposes.
24. RECAPTURE PROVISION
In the event the Subrecipient fails to expend funds under this Agreement in accordance with applicable
federal, state, and local laws, regulations, and/or the provisions of the Agreement, the Organization reserves
the right to recapture funds in an amount equivalent to the extent of noncompliance. Such right of recapture
shall exist for the life of the project following Agreement termination. Repayment by the Subrecipient of funds
under this recapture provision shall occur within 30 days of demand.
25. RECORDS
a. The Subrecipient agrees to maintain all books, records, documents, receipts, invoices and all other
electronic or written records necessary to sufficiently and properly reflect the Subrecipient's contracts,
subawards, grant administration, and payments.
b. The Subrecipient's records related to this Agreement and the projects funded may be inspected and
audited by the Organization or its designee, by the Office of the State Auditor, DHS, FEMA or their
designees, by the Comptroller General of the United States or its designees, or by other state or federal
officials authorized by law.
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c. The Subrecipient shall retain and allow access to all records related to this Agreement and the funded
project(s) for a period of at least six (6) years following final payment and closure of the grant under this
Agreement.
26. RESPONSIBILITY FOR PROJECT/STATEMENT OF WORK/WORK PLAN
While the Organization undertakes to assist the Subrecipient with the project/statement of work/work plan by
providing federal award funds pursuant to this Agreement, the project itself remains the sole responsibility of
the Subrecipient. The responsibility for the design, development, construction, implementation, operation and
maintenance of the project is solely that of the Subrecipient.
27. SEVERABILITY
If any court of rightful jurisdiction holds any provision or condition under this Agreement or its application to
any person or circumstances invalid, this invalidity does not affect other provisions, terms or conditions of the
Agreement, which can be given effect without the invalid provision.
28. SINGLE AUDIT ACT REQUIREMENTS (INCLUDING ALL AMENDMENTS)
Subrecipients of a federal award that expend $1,000,000 or more in one fiscal year of federal funds from all
sources are required to have a single or a program-specific audit conducted in accordance with 2 CFR Part
200 Subpart F. Subrecipients that spend less than $1,000,000 a year in federal awards are exempt from
federal audit requirements for that year. After the single audit has been completed, and if it includes any
audit findings, the Subrecipient must send a full copy of the audit and its Corrective Action Plan to the
Organization no later than the earlier of within 30 calendar days of receiving the auditor’s report of nine (9)
months after the end of the Subrecipient's fiscal year(s), addressed to: Contracts Office, Washington Military
Department, Finance Division, Building #1 TA-20, Camp Murray, WA 98430-5032, or
Contracts.Office@mil.wa.gov.
29. SUBRECIPIENT NOT EMPLOYEE
The Subrecipient, and/or employees or agents performing under this Agreement, are not employees or
agents of the Organization in any manner whatsoever. The Subrecipient will not be presented as nor claim to
be an officer or employee of the Organization or of the state of Washington by reason hereof.
30. TAXES, FEES AND LICENSES
Unless otherwise provided in this Agreement, the Subrecipient shall be responsible for, pay and maintain in
current status all taxes, unemployment contributions, fees, licenses, assessments, permit charges and
expenses of any other kind for the Subrecipient or its staff required by statute or regulation that are
applicable to Agreement performance.
31. TERMINATION FOR CONVENIENCE
Notwithstanding any provisions of this Agreement, the Subrecipient may terminate this Agreement by
providing written notice of such termination to the Organization Key Personnel identified in the Agreement,
specifying the effective date thereof, at least thirty (30) days prior to such date.
Except as otherwise provided in this Agreement, the Organization, in its sole discretion and in the best
interests of the state of Washington, may terminate this Agreement in whole or in part ten (10) business days
after emailing notice to the Subrecipient.
32. TERMINATION OR SUSPENSION FOR LOSS OF FUNDING
The Organization may unilaterally terminate or suspend all or part of this Grant Agreement, or may reduce its
scope of work and budget, if there is a reduction in funds by the source of those funds. The Organization will
email the Subrecipient ten (10) business days prior to termination.
33. TERMINATION OR SUSPENSION FOR CAUSE
In the event the Organization, in its sole discretion, determines the Subrecipient has failed to fulfill in a timely
and proper manner its obligations under this Agreement, is in an unsound financial condition, is in violation of
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any laws or regulations, or has violated any of the covenants, agreements or stipulations of this Agreement,
the Organization has the right to immediately suspend or terminate this Agreement in whole or in part.
34. TERMINATION PROCEDURES
In addition to the procedures set forth below, if the Organization terminates this Agreement, the Subrecipient
shall follow any procedures specified in the termination notice. Upon termination of this Agreement, the
Organization may require the Subrecipient to deliver to the Organization any property specifically produced
or acquired for the performance of such part of this Agreement as has been terminated.
After receipt of a notice of termination, and except as otherwise directed by the Organization in writing, the
Subrecipient shall: stop work under the Agreement; place no further orders or contracts for materials or
services; assign rights to the Organization; settle all outstanding liabilities; transfer title to the Organization;
complete performance of such part of the work not terminated; and take action for the protection and
preservation of the property related to this Agreement.
35. MINORITY AND WOMEN-OWNED BUSINESS ENTERPRISES
In accordance with Chapter 39.19 RCW, the state of Washington encourages participation in all its contracts
by MWBE firms certified by the Office of Minority and Women's Business Enterprises (OMWBE). Voluntary
numerical MWBE participation goals have been established: Minority Business Enterprises (MBE's): 10%
and Women's Business Enterprises (WBE's): 6%.
36. VENUE
This Agreement shall be construed and enforced in accordance with, and the validity and performance shall
be governed by, the laws of the state of Washington and all applicable federal laws. Except as provided
otherwise herein, venue for any dispute between the parties arising out of this Agreement shall be in King
County, Washington.
37. WAIVERS
No conditions or provisions of this Agreement can be waived unless approved in advance by the
Organization in writing. The Organization's failure to insist upon strict performance of any provision of the
Agreement or to exercise any right based upon a breach thereof shall not constitute a waiver of any right
under this Agreement.
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ATTACHMENT C
DHS AWARD LETTER
Award Number: EMW-2026-WC-05005
The DHS Award Letter for Grant No. EMW-2026-WC-05005 is incorporated herein by reference. This award
consists of funding in the amount of $32,252,845.00 to the SeattleFWC26 as Recipient and Pass-through
Entity for the FY 2026 FIFA World Cup Grant Program.
Award Leer
U.S. Department of Homeland Security
Washington, D.C. 20472
Effecve date: 03/18/2026
Kathryn Zetzer
MILITARY DEPARTMENT, WASHINGTON STATE
BUILDING 1 MILITIA DR STATE FINANCIAL SERVICES CAMP MURRAY, WA
98430
EMW-2026-WC-05005
Dear Kathryn Zetzer,
Congratulaons on behalf of the Department of Homeland Security, your applicaon submied for the FIFA World Cup
Grant Program, has been approved in the amount of $32,252,845.00 in Federal funding. This award of federal assistance
is executed as a Grant.
Before you request and receive any of the Federal funds awarded to you, you must establish acceptance of the award
through the FEMA Grants Outcomes (FEMA GO) system. By accepng this award, you acknowledge that the terms of the
following documents are incorporated into the terms of your award:
Award Summary - included in this document
Agreement Arcles - included in this document
Obligang Document - included in this document
FIFA World Cup Grant Program (FWCGP) Noce of Funding Opportunity The Preparedness
Grant Manual (PGM)
Please make sure you read, understand, and maintain a copy of these documents in your official le for this award.
Sincerely,
David Gudinas
Deputy Assistant Administrator (Acng)
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Grant Programs Directorate | Resilience
Award Summary
Program: Fiscal Year 2026 FIFA World Cup Grant Program
Recipient: MILITARY DEPARTMENT, WASHINGTON STATE
UEI-EFT: D2EJRGZ2PLG8 Award number: EMW-
2026-WC-05005
Summary descripon of award
In 2026, the United States, Canada, and Mexico will host the 2026 World Cup. This event will be hosted across 11 ci es in
the United States with 78 U.S.-based matches making up an extensive series of highrisk events. The FIFA World Cup Grant
Program (FWCGP) makes funds available to host cies through governor-designated State Administrave Agencies (SAA),
to carry out the extensive security acvies required to protect players, staff, aendees, venues, and crical
infrastructure across the host cies strengthening them against potenal terrorist aacks.
Amount awarded table
The amount of the award is detailed in the aached Obligang Document for Award.
The following are the budgeted esmates for object classes for this award (including Federal share plus your cost share, if
applicable):
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Approved scope of work
Aer review of your applicaon, FEMA has approved the below scope of work. Juscaons are provided for any
differences between the scope of work in the original applicaon and the approved scope of work under this award. You
must submit scope or budget revision requests for FEMA's prior approval, via an amendment request, as appropriate per
2 C.F.R. § 200.308 and the FY2026 FWCGP NOFO.
Approved request details:
Investment
Developing and enhancing plans and protocols
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DESCRIPTION
Planning: Funds will support a mul-agency effort to develop, rene, and exercise jurisdiconal
Concepts of Operaons (CONOPS) and venue specic security plans for Seale’s six 2026 FIFA World Cup
matches and associated fan acvies. The planning and execuve steering commiees will connue to
convene to guide work, resolve cross cung issues, and conduct nal reviews of all major planning
documents. Jurisdiconal CONOPS and venue specic security plans will be nalized, approved, and tested
through exercises to ensure they are operaonally sound and to surface any residual gaps requiring
adjustments to plans, staffing, or mutual aid arrangements. Together, these completed and planned ac vies
demonstrate why advance planning is essenal and how the region is systemacally building the plans,
protocols, and assessments needed to deliver a safe and secure World Cup.
QUANTITY UNIT PRICE TOTAL
1 $1,838,174.00 $1,838,174.00
BUDGET CLASS
Other
Operaonal support
DESCRIPTION
Organizaon: Funds will be used for operaonal overme for law enforcement and emergency responders,
overme and backll for EOC/ICP/JIC/Fusion Center staff, EMAC/PNEMA mutual aid deployments, and staffing
to sustain mul agency governance and coordinaon structures ed to World Cup operaons.
QUANTITY UNIT PRICE TOTAL
1 $22,192,382.00 $22,192,382.00
BUDGET CLASS
Other
Other Authorized Equipment
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DESCRIPTION
Equipment: Planned and completed acvies for allowable equipment focus on hardening tournament
venues, supporng safe crowd movement, and enabling rapid response to emergencies, with equipment
deployed during dened World Cup operaonal periods. Based on venue assessments and security
planning, the jurisdicon is idenfying specic equipment and resource requirements needed to ensure
safe and secure tournament events at stadiums, fan acvaons, pracce facilies, base camps, hotels, and
key transporta on nodes.
QUANTITY UNIT PRICE TOTAL
1 $6,309,647.00 $6,309,647.00
BUDGET CLASS
Other
Training workshops and conferences
DESCRIPTION
Training: Funds will support a mix of DHS/FEMA sponsored courses, specialized summits and conferences, and
World Cup–focused workshops that build the knowledge, skills, and partnerships needed to prepare for,
protect against, and respond to threats and emergencies during tournament operaons. Training acvies
will target law enforcement, re/EMS, emergency management, public health, transportaon, and venue
security personnel who will play direct operaonal and planning roles for World Cup events.
QUANTITY UNIT PRICE TOTAL
1 $150,000.00 $150,000.00
BUDGET CLASS
Other
Hiring of full- or part-me staff or contractors/consultants to assist with the
management of the respecve grant program, applicaon requirements, and
compliance with reporng and data collecon requirements
Design, Develop, Conduct, and Evaluate an Exercise
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DESCRIPTION
Exercise: Acvies will test and strengthen mass casualty, stadium, and transportaon response plans that
support World Cup operaons, using allowable exercise costs to ensure each exercise is fully designed,
conducted, and evaluated in a standardized way. All exercises will be managed as Homeland Security Exercise
and Evaluaon Program (HSEEP)–compliant acvies to produce aconable aer-acon reports and
improvement plan that directly inform updates to plans, procedures, and training priori es. FWCGP funds will
provide exibility to support addional HSEEP compliant exercises that are idened through ongoing
planning and operaonal needs, provided they align with FWCGP NOFO requirements.
QUANTITY UNIT PRICE TOTAL
1 $150,000.00 $150,000.00
BUDGET CLASS
Other
Agreement Arcles
Program: Fiscal Year 2026 FIFA World Cup Grant Program
Recipient: MILITARY DEPARTMENT, WASHINGTON STATE
UEI-EFT: D2EJRGZ2PLG8 Award number: EMW-
2026-WC-05005
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Table of contents
Arcle Assurance, Administrave Requirements, Cost Principles, Representaons, and
Cercaons
1
Arcle General Acknowledgements and Assurances
2
Arcle Acknowledgement of Federal Funding from DHS
3
Arcle Acvies Conducted Abroad
4
Arcle Age Discriminaon Act of 1975 5
Arcle Americans with Disabilies Act of 1990
6
Arcle Best Pracces for Collecon and Use of Personally Idenable Informaon
7
Arcle CHIPS and Science Act of 2022, Public Law 117-167 CHIPS
8
Arcle Civil Rights Act of 1964 – Title VI
9
Arcle Civil Rights Act of 1968
10
Arcle Communicaon and Cooperaon with the Department of Homeland Security and
11
Immigraon Officials
Arcle Copyright
12
Arcle Debarment and Suspension
13
Arcle Drug-Free Workplace Regulaons 14
Arcle Duplicave Costs
15
Arcle Educaon Amendments of 1972 (Equal Opportunity in Educaon Act) – Title IX 16
Arcle Energy Policy and Conservaon Act 17
Arcle Equal Treatment of Faith-Based Organizaons 18
Arcle An-Discriminaon
19
Arcle False Claims Act and Program Fraud Civil Remedies 20
Arcle Federal Debt Status
21
Arcle Federal Leadership on Reducing Text Messaging while Driving 22
Arcle Fly America Act of 1974
23
Arcle Hotel and Motel Fire Safety Act of 1990 24
Arcle John S. McCain Naonal Defense Authorizaon Act of Fiscal Year 2019 25
Arcle Limited English Prociency (Civil Rights Act of 1964, Title VI) 26
Arcle Lobbying Prohibions 27
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Arcle Naonal Environmental Policy Act
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28
Arcle Naonal Security Presidenal Memorandum-33 (NSPM-33) and provisions of the
29 CHIPS and Science Act of 2022, Pub. L. 117-167, Secon 10254
Arcle Non-Supplanng Requirement
30
Arcle Noce of Funding Opportunity Requirements
31
Arcle Patents and Intellectual Property Rights
32
Arcle Presidenal Execuve Orders
33
Arcle Procurement of Recovered Materials
34
Arcle Rehabilitaon Act of 1973
35
Arcle Reporng Recipient Integrity and Performance Maers
36
Arcle Reporng Subawards and Execuve Compensaon 37
Arcle Required Use of American Iron, Steel, Manufactured Products, and Construcon
38 Materials
Arcle SAFECOM
39
Arcle Subrecipient Monitoring and Management
40
Arcle System for Award Management and Unique Enty Idener Requirements 41
Arcle Terminaon of a Federal Award
42
Arcle Terrorist Financing
43
Arcle Trafficking Vicms Protecon Act of 2000(TVPA)
44
Arcle Uning and Strengthening America by Providing Appropriate Tools Required to
45 Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001, Pub. L. 107-56
Arcle Use of DHS Seal, Logo and Flags
46
Arcle Whistleblower Protecon Act
47
Arcle Environmental Planning and Historic Preservaon (EHP) Review 48
Arcle Applicability of DHS Standard Terms and Condions to Tribal Naons 49
Arcle Acceptance of Post Award Changes
50
Arcle Disposion of Equipment Acquired Under the Federal Award 51
Arcle Prior Approval for Modicaon of Approved Budget 52
Arcle Indirect Cost Rate
53
Arcle Build America, Buy America Act (BABAA) Required Contract Provision & Self54 Cercaon
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Arcle Summary Descripon of Award 55
Arcle Non-Applicability of Specic Agreement Arcles 56
Arcle Non-Applicability of Specic Terms and Agreement Arcles Pursuant to County of 57 Santa Clara, et al.
v. Noem, et al.
Arcle Non-Applicability of Specic Terms and Agreement Arcles Pursuant to City of 58 Chicago et al.
v. Noem, et al.
Arcle Non-Applicability of Specic Terms and Agreement Arcles Pursuant to City of Seale 59 v. Trump,
et al.
Arcle Expedited Review of Amendments 60
Arcle Reducing Pass-Through Time
61
Arcle Prohibion on Covered Foreign Unmanned Aircra Systems (UAS) 62
Arcle Award Compliance Hold 63
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Arcle 1
Assurance, Administrave Requirements, Cost Principles, Representaons, and Cercaons
I. Recipients must complete either the Office of Management and Budget (OMB)
Standard Form 424B Assurances – Non- Construcon Programs, or OMB Standard Form 424D
Assurances – Construcon Programs, as applicable. Certain assurances in these documents
may not be applicable to your program and the DHS nancial assistance office (DHS FAO) may
require applicants to cerfy addional assurances.
Applicants are required to ll out the assurances, as instructed.
Arcle 2
General Acknowledgements and Assurances
Recipients are required to follow the applicable provisions of the Uniform
Administrave Requirements, Cost Principles, and Audit Requirements for Federal
Awards in effect as of the federal award date and located in Title 2, Code of Federal
Regulaons, Part 200 and adopted by DHS at 2 C.F.R. § 3002.10. All recipients and
subrecipients must acknowledge and agree to provide DHS access to records, accounts,
documents, informaon, facilies, and staff pursuant to 2 C.F.R. § 200.337. I. Recipients must
cooperate with any DHS compliance reviews or compliance invesgaons. II. Recipients must
give DHS access to examine and copy records, accounts, and other documents and sources of
informaon related to the federal award and permit access to facilies and personnel. III.
Recipients must submit mely, complete, and accurate reports to the appropriate DHS
officials and maintain appropriate backup documentaon to support the reports. IV.
Recipients must comply with all other special repor ng, data collecon, and evaluaon
requirements required by law, federal regulaon, Noce of Funding Opportunity, federal
award specic terms and condions, and/or DHS Component program guidance.
Organizaon costs related to data and evaluaon are allowable. The denion of data and
evaluaon costs is in 2 C.F.R. § 200.455(c), the full text of which is incorporated by reference.
V. Recipients must complete DHS Form 3095 within 60 days of receipt of the Noce of Award
for the rst award under which this term applies. For further instrucons and to access the
form, please visit: hps://www.dhs.gov/civil-rightsresources-recipientsdhs-nancial-
assistance.
Arcle 3
Acknowledgement of Federal Funding from DHS
Recipients must acknowledge their use of federal award funding when issuing statements,
press releases, requests for proposal, bid invitaons, and other documents describing
projects or programs funded in whole or in part with federal award funds.
Arcle 4
Acvies Conducted Abroad
Recipients must coordinate with appropriate government authories when performing project
acvies outside the United States obtain all appropriate licenses, permits, or approvals.
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Arcle 5 Age Discriminaon Act of 1975
Recipients must comply with the requirements of the Age Discriminaon Act of 1975, Pub. L.
No. 94-135 (codied as amended at Title 42, U.S. Code § 6101 et seq.), which prohibits
discriminaon on the basis of age in any program or acvity receiving federal nancial
assistance.
Arcle 6
Americans with Disabilies Act of 1990
Recipients must comply with the requirements of Titles I, II, and III of the Americans with
Disabilies Act, Pub. L. No. 101-336 (1990) (codied as amended at 42 U.S.C. §§ 12101–
12213), which prohibits recipients from discriminang on the basis of disability in the
operaon of public enes, public and private transportaon systems, places of public
accommodaon, and certain tesng enes.
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Arcle 7 Best Pracces for Collecon and Use of Personally Idenable Informaon (1) Recipients
who collect personally idenable informaon (PII) as part of carrying out the scope of work
under a federal award are required to have a publicly available privacy policy that describes
standards on the usage and maintenance of the PII they collect. (2) Denion. DHS denes
PII” as any informaon that permits the identy of an individual to be directly or indirectly
inferred, including any informaon that is linked
or linkable to that individual. Recipients may also nd the DHS Privacy Impact Assessments:
Privacy Guidance and Privacy Template as useful resources respecvely.
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Arcle 8
CHIPS and Science Act of 2022, Public Law 117-167 CHIPS
1) Recipients of DHS research and development (R&D) awards must report to the DHS
Component research program office any nding or determinaon of sex based and sexual
harassment and/or an administrave or disciplinary acon taken against principal
invesgators or co-invesgators to be completed by an authorized organizaonal
representave (AOR) at the recipient instuon. (2) Nocaon. An AOR must disclose the
following informaon to agencies within 10 days of the date/the nding is made, or 10 days
from when a recipient imposes an administrave acon on the reported individual,
whichever is sooner. Reports should include: (a)
Award number, (b) Name of PI or Co-PI being reported, (c) Awardee name, (d) Awardee
address, (e) AOR name, tle, phone, and email address, (f) Indicaon of the report type: (i)
Finding or determinaon has been made that the reported individual violated awardee
policies or codes of conduct, statutes, or regulaons related to sexual harassment, sexual
assault, or other forms of harassment, including the date that the nding was made. (ii)
Imposion of an administrave or disciplinary acon by the recipient on the reporng
individual related to a nding/determinaon or an invesgaon of an alleged violaon of
recipient policy or codes of conduct, statutes, or regulaons, or other forms of harassment.
iii) The date and nature of the
administrave/disciplinary acon, including a basic explanaon or descripon of the event,
which should not disclose personally idenable informaon regarding any complaints or
individuals involved. Any descripon provided must be consistent with the Family
Educaonal Rights in Privacy Act. (3) Denions. (a) An “authorized organizaonal
representave (AOR)” is an administrave official who, on behalf of the proposing instuon,
is empowered to make cercaons and representaons and can commit the instuon to
the conduct of a project that an agency is being asked to support as well as adhere to various
agency policies and award requirements. (b) “Principal invesgators and co-principal
invesgators” are award personnel supported by a grant, cooperave agreement, or contract
under Federal law. (c) A “reported individual” refers to recipient personnel who have been
reported to a federal agency for potenal sexual harassment violaons. (d) “Sex based
harassment” means a form of sex discriminaon and includes harassment based on sex, sex
stereotypes, sex characteriscs, pregnancy or related condions, sexual orientaon, and
gender identy. (e) “Sexual harassment” means unwelcome sexual advances, requests for
sexual favors, and other verbal or physical conduct of a sexual nature when this conduct
explicitly or implicitly affects an individual’s employment, unreasonably interferes with an
individual’s work performance, or creates an inmidang, hosle, or offensive work
environment, whether such acvity is carried out by a supervisor or by a co-worker,
volunteer, or contractor.
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Arcle 9 Civil Rights Act of 1964 – Title VI
Recipients must comply with the requirements of Title VI of the Civil Rights Act of 1964, Pub.
L. No. 88-352 (codied as amended at 42 U.S.C. § 2000d et seq.), which provides that no
person in the United States will, on the grounds of race, color, or naonal origin, be excluded
from parcipaon in, be denied the benets of, or be subjected to discriminaon under any
program or acvity receiving federal nancial assistance. DHS implemenng regulaons for
the Act are found at 6 C.F.R. Part 21. Recipients of a federal award from the Federal
Emergency Management Agency
FEMA) must also comply with FEMA’s implemenng regulaons at 44 C.F.R. Part 7.
Arcle 10
Civil Rights Act of 1968
Recipients must comply with Title VIII of the Civil Rights Act of 1968, Pub. L. No. 90284
codied as amended at 42 U.S.C. § 3601 et seq.) which prohibits recipients from
discriminang in the sale, rental, nancing, and adver sing of dwellings, or in the provision
of services in connecon. therewith, on the basis of race, color, naonal origin, religion,
disability, familial status, and sex, as implemented by the U.S. Department of Housing and
Urban Development at 24 C.F.R. Part 100. The prohibion on disability discriminaon
includes the requirement that new mulfamily housing with four or more dwelling units—
i.e., the public and common use areas and individual apartment units (all units in buildings
with elevators and ground-oor units in buildings without elevators)—be designed and
constructed with certain accessible features. (See 24 C.F.R. Part 100, Subpart D.)
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Arcle 11 Communicaon and Cooperaon with the Department of Homeland Security and
Immigraon Officials
1) All recipients and other recipients of funds under this award must agree that they will
comply with the following requirements related to coordinaon and cooperaon with the
Department of Homeland Security and immigraon officials: (a) They must comply with the
requirements of 8 U.S.C. §§ 1373 and 1644. These statutes prohibit restricons on
informaon sharing by state and local government enes with DHS regarding the cizenship
or immigraon status, lawful or unlawful, of any individual. Addionally, 8 U.S.C. § 1373
prohibits any person or agency from prohibing, or in any way restricng, a Federal, State, or
local government enty from doing any of the following with respect to informaon
regarding the immigraon status of any individual: 1) sending such informaon to, or
requesng or receiving such informaon from, Federal immigraon officials; 2) maintaining
such informaon; or 3) exchanging such informaon with any other Federal, State, or local
government enty; (b) They must comply with other relevant laws related to immigraon,
including prohibions on encouraging or inducing an alien to come to, enter, or reside in the
United States in violaon of law, 8 U.S.C. § 1324(a)(1)(A)(iv), prohibions on transporng or
moving illegal aliens, 8 U.S.C. § 1324(a)(1)(A)(ii), prohibi ons on harboring, concealing, or
shielding from detecon illegal aliens, 8 U.S.C. § 1324(a)(1)(A)(iii), and any applicable
conspiracy, aiding or abeng, or aempt liability regarding these statutes; (c) That they will
honor requests for cooperaon, such as parcipaon in joint operaons, sharing of
informaon, or requests for short term detenon of an alien pursuant to a valid detainer. A
jurisdicon does not fail to comply with this requirement merely because it lacks the
necessary resources to assist in a parcular instance; (d) That they will provide access to
detainees, such as when an immigraon officer seeks to interview a person who might be a
removable alien; and (e) That they will not leak or otherwise publicize the existence of an
immigraon enforcement operaon. (2) The recipient must cerfy under penalty of perjury
pursuant to 28 U.S.C. § 1746 and using a form that is acceptable to DHS, that it will comply
with the requirements of this term. Addionally, the recipient agrees that it will require any
subrecipients or contractors to cerfy in the same manner that they will comply with this
term prior to providing them with any funding under this award. (3) The recipient agrees that
compliance with this term is material to the Government’s decision to make or con nue with
this award and that the Department of homeland Security may terminate this grant, or take
any other allowable enforcement acon, if the recipient fails to comply with this term.
Arcle 12
Copyright
Recipients must affix the applicable copyright no ces of 17 U.S.C. §§ 401 or 402 to any work
rst produced under federal awards and also include an acknowledgement that the work was
produced under a federal award (including the federal award number and federal awarding
agency). As detailed in 2 C.F.R. § 200.315, a federal awarding agency reserves a royalty-free,
nonexclusive, and irrevocable right to reproduce, publish, or otherwise use the work for
federal purposes and to authorize others to do so.
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Arcle 13
Debarment and Suspension
Recipients must comply with the non-procurement debarment and suspension regulaons
implemenng Execuve Orders 12549 and 12689 set forth at 2 C.F.R. Part 180 as
implemented by DHS at 2 C.F.R. Part 3000. These regulaons prohibit recipients from
entering into covered transacons (such as subawards and contracts) with certain pares
that are debarred, suspended, or otherwise excluded from or ineligible for parcipaon in
federal assistance programs or acvies.
Arcle 14
Drug-Free Workplace Regulaons
Recipients must comply with drug-free workplace requirements in Subpart B (or
Subpart C, if the recipient is an individual) of 2 C.F.R. Part 3001, which adopts the
Government- wide implementaon (2 C.F.R. Part 182) of the Drug-Free Workplace Act of
1988 (41 U.S.C. §§ 8101-8106).
Arcle 15
Duplicave Costs
Recipients are prohibited from charging any cost to this federal award that will be included as
a cost or used to meet cost sharing requirements of any other federal award in either the
current or a prior budget period. See 2 C.F.R. § 200.403(f). However, recipients may shi costs
that are allowable under two or more federal awards where otherwise permied by federal
statutes, regulaons, or the federal award terms and condions.
Arcle 16
Educaon Amendments of 1972 (Equal Opportunity in Educaon Act) – Title IX
Recipients must comply with the requirements of Title IX of the Educaon
Amendments of 1972, Pub. L. No. 92-318 (codied as amended at 20 U.S.C. § 1681 et seq.),
which provide that no person in the United States will, on the basis of sex, be excluded from
parcipaon in, be denied the benets of, or be subjected to discriminaon under any
educaonal program or acvity receiving federal nancial assistance. DHS implemenng
regulaons are codied at 6 C.F.R. Part 17. Recipients of a federal award from the Federal
Emergency Management Agency (FEMA) must also comply with FEMA’s implemenng
regulaons at 44 C.F.R. Part 19.
Arcle 17 Energy Policy and Conservaon Act
Recipients must comply with the requirements of the Energy Policy and Conserva on Act, Pub.
L. No. 94-163 (1975) (codied as amended at 42 U.S.C. § 6201 et seq.), which contain policies
relang to energy efficiency that are dened in the state energy conservaon plan issued in
compliance with this Act.
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Arcle 18
Equal Treatment of Faith-Based Organizaons
It is DHS policy to ensure the equal treatment of faith-based organizaons in social service
programs administered or supported by DHS or its component agencies, enabling those
organizaons to parcipate in providing important social services to beneciaries. Recipients
must comply with the equal treatment policies and requirements contained in 6 C.F.R. Part 19
and other applicable statutes, regulaons, and guidance governing the parcipaons of faith-
based organizaons in individual DHS programs.
Arcle 19
An-Discriminaon
Recipients must comply with all applicable Federal an-discriminaon laws material to the
government’s payment decisions for purposes of 31 U.S.C. § 372(b)(4). (1) Denions. As
used in this clause – (a) DEI means “diversity, equity, and inclusion.” (b) DEIA means
diversity, equity, inclusion, and accessibility.” (c) Discriminatory equity ideology has the
meaning set forth in Secon 2(b) of Execuve Order 14190 of January 29, 2025. (d) Federal
an-discriminaon laws mean Federal civil rights law that protect individual Americans from
discriminaon on the basis of race, color, sex, religion, and naonal origin. (e) Illegal
immigrant means any alien, as dened in 8 U.S.C. § 1101(a)(3), who has no lawful
immigraon status in the United States.(2) Grant award cercaon. (a) By accepng the
grant award, recipients are cerfying that: (i) They do not, and will not during the term of this
nancial assistance award, operate any programs that advance or promote DEI, DEIA, or
discriminatory equity ideology in violaon of Federal an-discriminaon laws; and (ii) They
do not engage in and will not during the term of this award engage in, a discriminatory
prohibited boyco. (iii) They do not, and will not during the term of this award, operate any
program that benets illegal immigrants or incenvizes illegal immigraon. (3) DHS reserves
the right to suspend payments in whole or in part and/or terminate nancial assistance
awards if the Secretary of Homeland Security or her designee determines that the recipient
has violated any provision of subsecon (2). (4) Upon suspension or terminaon under
subsecon (3), all funds received by the recipient shall be deemed to be in excess of the
amount that the recipient is determined to be entled to under the Federal award for
purposes of 2 C.F.R. § 200.346. As such, all amounts received will cons tute a debt to the
Federal Government that may be pursued to the maximum extent permied by law.
Arcle 20
False Claims Act and Program Fraud Civil Remedies
Recipients must comply with the requirements of the False Claims Act, 31 U.S.C. §§ 3729-
3733, which prohibit the submission of false or fraudulent claims for payment to the Federal
Government. (See 31 U.S.C. §§ 3801-3812, which details the administrave remedies for false
claims and statements made.)
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Arcle 21 Federal Debt Status
All recipients are required to be non-delinquent in their repayment of any federal debt.
Examples of relevant debt include delinquent payroll and other taxes, audit disallowances, and
benet overpayments. See OMB Circular A-129.
Arcle 22
Federal Leadership on Reducing Text Messaging while Driving
Recipients are encouraged to adopt and enforce policies that ban text messaging while
driving recipient-owned, recipient-rented, or privately owned vehicles when on official
government business or when performing any work for or on behalf of the Federal
Government. Recipients are also encouraged to conduct the ini aves of the type described
in Secon 3(a) of Execuve Order 13513.
Arcle 23
Fly America Act of 1974
Recipients must comply with Preference for U.S. Flag Air Carriers (a list of cer ed air carriers
can be found at: Cercated Air Carriers List | US Department of
Transportaon, hps://www.transportaon.gov/policy/aviaon-policy/cercatedaircarriers-
list)for internaonal air transportaon of people and property to the extent that such service
is available, in accordance with the Internaonal Air Transportaon Fair Compeve Pracces
Act of 1974, 49 U.S.C. § 40118, and the interpretave guidelines issued by the Comptroller
General of the United States in the March 31, 1981, amendment to Comptroller General
Decision B-138942.
Arcle 24
Hotel and Motel Fire Safety Act of 1990
Recipients must ensure that all conference, meeng, convenon, or training space funded
enrely or in part by federal award funds complies with the re prevenon and control
guidelines of Secon 6 of the Hotel and Motel Fire Safety Act of 1990, 15 U.S.C. § 2225a.
Arcle 25
John S. McCain Naonal Defense Authorizaon Act of Fiscal Year 2019
Recipients, subrecipients, and their contractors and subcontractors are subject to the
prohibions described in secon 889 of the John S. McCain Naonal Defense Authorizaon
Act for Fiscal Year 2019, Pub. L. No. 115-232 (2018) and 2 C.F.R. §§ 200.216, 200.327, 200.471,
and Appendix II to 2 C.F.R. Part 200. The statute – as it applies to DHS recipients, subrecipients,
and their contractors and subcontractors – prohibits obligang or expending federal award
funds on certain telecommunicaons and video surveillance products and contrac ng with
certain enes for naonal security reasons.
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Arcle 26 Limited English Prociency (Civil Rights Act of 1964, Title VI)
Recipients must comply with Title VI of the Civil Rights Act of 1964 (42 U.S.C. § 2000d et seq.)
prohibion against discriminaon on the basis of naonal origin, which requires that
recipients of federal nancial assistance take reasonable steps to provide meaningful access
to persons with limited English prociency (LEP) to their programs and services. For
addional assistance and informaon regarding language access obligaons, please refer to
the DHS Recipient Guidance:
hps://www.dhs.gov/guidance-published-help- department-supportedorganizaonsprovide-
meaningful-access-people-limited and addional resources on hp://www.lep.gov.
Arcle 27
Lobbying Prohibions
Recipients must comply with 31 U.S.C. § 1352 and 6 C.F.R. Part 9, which provide that none of
the funds provided under a federal award may be expended by the recipient to pay any
person to inuence, or aempt to inuence an officer or employee of any agency, a Member
of Congress, an officer or employee of Congress, or an employee of a Member of Congress in
connecon with any federal acon related to a federal award or contract, including any
extension, connuaon, renewal, amendment, or modicaon. Per 6 C.F.R. Part 9, recipients
must le a lobbying cercaon form as described in Appendix A to 6 C.F.R. Part 9 or
available on Grants.gov as the Grants.gov Lobbying Form and le a lobbying disclosure form
as described in Appendix B to 6 C.F.R. Part 9 or available on Grants.gov as the Disclosure of
Lobbying Acvies (SF-LLL).
Arcle 28
Naonal Environmental Policy Act
Recipients must comply with the requirements of the Naonal Environmental Policy Act of
1969, Pub. L. No. 91-190 (1970) (codied as amended at 42 U.S.C. § 4321 et seq.) (NEPA) and
the Council on Environmental Quality (CEQ) Regulaons for Implemenng the Procedural
Provisions of NEPA, which require recipients to use all praccable means within their
authority, and consistent with other essenal consideraons of naonal policy, to create and
maintain condions under which people and nature can exist in produc ve harmony and
fulll the social, economic, and other needs of present and future generaons of Americans.
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Arcle 29
Naonal Security Presidenal Memorandum-33 (NSPM-33) and provisions of the CHIPS and
Science Act of 2022, Pub. L. 117-167, Secon 10254
1) Recipient research instuons (“covered instuons”) must comply with the requirements
in NSPM-33 and provisions of Pub. L.117-167, Secon 10254 (codied at 42 U.S.C. § 18951)
cerfying that the instuon has established and operates a research security program that
includes elements relang to: (a) cybersecurity; (b) foreign travel security; (c) research security
training; and (d) export control training, as appropriate. (2) Deni on. “Covered instuons”
means recipient research instuons receiving federal Research and Development (R&D)
science and engineering support
in excess of $50 million per year.”
Arcle 30
Non-Supplanng Requirement
Recipients of federal awards under programs that prohibit supplanng by law must ensure
that federal funds supplement but do not supplant non-federal funds that, in the absence of
such federal funds, would otherwise have been made available for the same purpose.
Arcle 31 Noce of Funding Opportunity Requirements
All the instrucons, guidance, limitaons, scope of work, and other condions set forth in
the Noce of Funding Opportunity (NOFO) for this federal award are incorporated by
reference. All recipients must comply with any such requirements set forth in the NOFO. If a
condion of the NOFO is inconsistent with these terms and condions and any such terms of
the federal award, the condion in the NOFO shall be invalid to the extent of the
inconsistency. The remainder of that condion and all other condions set forth in the NOFO
shall remain in effect.
Arcle 32
Patents and Intellectual Property Rights
Recipients are subject to the Bayh-Dole Act, 35 U.S.C. § 200 et seq. and applicable regulaons
governing invenons and patents, including the regulaons issued by the
Department of Commerce at 37 C.F.R. Part 401 (Rights to Invenons Made by
Nonprot Organizaons and Small Business Firms under Government Awards, Contracts, and
Cooperave Agreements) and the standard patent rights clause set forth at 37 C.F.R. § 401.14.
Arcle 33
Presidenal Execuve Orders
Recipients must comply with the requirements of Presidenal Execuve Orders related to
grants (also known as federal assistance and nancial assistance), the full text of which are
incorporated by reference.
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Arcle 34
Procurement of Recovered Materials
States, polical subdivisions of states, and their contractors must comply with Sec on
6002 of the Solid Waste Disposal Act, Pub. L. No. 89-272 (1965) (codied as
amended by the Resource Conservaon and Recovery Act at 42 U.S.C. § 6962) and 2 C.F.R. §
200.323. The requirements of Secon 6002 include procuring only items designated in
guidelines of the Environmental Protecon Agency (EPA) at 40 C.F.R. Part 247 that contain the
highest percentage of recovered materials praccable, consistent with maintaining a
sasfactory level of compeon.
Arcle 35
Rehabilitaon Act of 1973
Recipients must comply with the requirements of Secon 504 of the Rehabilitaon Act of
1973, Pub. L. No. 93-112 (codied as amended at 29 U.S.C. § 794), which provides that no
otherwise qualied handicapped individuals in the United States will, solely by reason of the
handicap, be excluded from parcipaon in, be denied the benets of, or be subjected to
discriminaon under any program or acvity receiving federal nancial assistance.
Arcle 36
Repor ng Recipient Integrity and Performance Maers
If the total value of any currently acve grants, cooperave agreements, and procurement
contracts from all federal awarding agencies exceeds $10,000,000 for any period of me
during the period of performance of the federal award, then the recipient must comply with
the requirements set forth in the government-wide federal award term and condion for
Recipient Integrity and Performance Maers is in 2 C.F.R. Part 200, Appendix XII, the full text
of which is incorporated by reference.
Arcle 37 Repor ng Subawards and Execuve Compensaon
For federal awards that total or exceed $30,000, recipients are required to comply with the
requirements set forth in the government-wide federal award term and condion on
Reporng Subawards and Execuve Compensaon set forth at 2 C.F.R. Part 170, Appendix A,
the full text of which is incorporated by reference.
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Arcle 38
Required Use of American Iron, Steel, Manufactured Products, and Construcon Materials
1) Recipients of a federal award from a nancial assistance program that provides funding
for infrastructure are hereby noed that none of the funds provided under this federal
award may be used for a project for infrastructure unless: (a) all iron and steel used in the
project are produced in the United States—this means all manufacturing processes, from the
inial melng stage through the applicaon of coangs, occurred in the United States; (b) all
manufactured products used in the project are produced in the United States—this means
the manufactured product was manufactured in the United States; and the cost of the
components of the manufactured product that are mined, produced, or manufactured in the
United States is greater than 55 percent of the total cost of all components of the
manufactured product, unless another standard for determining the minimum amount of
domesc content of the manufactured product has been established under applicable law or
regulaon; and (c) all construcon materials are manufactured in the United States—this
means that all manufacturing processes for the construcon material occurred in the United
States. (2) The Buy America preference only applies to arcles, materials, and supplies that
are consumed in, incorporated into, or affixed to an infrastructure project. As such, it does
not apply to tools, equipment, and supplies, such as temporary scaffolding, brought to the
construcon site and removed at or before the compleon of the infrastructure project. Nor
does a Buy America preference apply to equipment and furnishings, such as movable chairs,
desks, and portable computer equipment, that are used at or within the nished
infrastructure project but are not an integral part of the structure or permanently affixed to
the infrastructure project. (3) Waivers When necessary, recipients may apply for, and the
agency may grant, a waiver from these requirements. The agency should nofy the recipient
for informaon on the process for requesng a waiver from these requirements. (a) When
the Federal agency has determined that one of the following excepons applies, the federal
awarding official may waive the applicaon of the domesc content procurement preference
in any case in which the agency determines that: (i) applying the domesc content
procurement preference would be inconsistent with the public interest; (ii) the types of iron,
steel, manufactured products, or construcon materials are not produced in the United
States in sufficient and reasonably available quanes or of a sasfactory quality; or (iii) the
inclusion of iron, steel, manufactured products, or construcon materials produced in the
United States will increase the cost of the overall project by more than 25 percent. (b) A
request to waive the applicaon of the domesc content procurement preference must be in
wring. The agency will provide instrucons on the format, contents, and supporng
materials required for any waiver request. Waiver requests are subject to public comment
periods of no less than 15 days and must be reviewed by the Made in America Office. (c)
There may be instances where a federal award qualies, in whole or in part, for an exisng
waiver described at “Buy America” Preference in FEMA Financial Assistance Programs for
Infrastructure | FEMA.gov. (4) Denions. The denions applicable to this term are set forth
at 2 C.F.R. § 184.3, the full text of which is incorporated by reference.
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Arcle 39 SAFECOM
Recipients receiving federal awards made under programs that provide emergency
communicaon equipment and its related acvies must comply with the SAFECOM Guidance
for Emergency Communicaon Grants, including provisions on technical standards that ensure
and enhance interoperable communicaons. The SAFECOM
Guidance is updated annually and can be found at Funding and Sustainment | CISA.
Arcle 40
Subrecipient Monitoring and Management
Pass-through enes must comply with the requirements for subrecipient monitoring and
management as set forth in 2 C.F.R. §§ 200.331-333.
Arcle 41
System for Award Management and Unique Enty Idener Requirements Recipients are
required to comply with the requirements set forth in the
governmentwide federal award term and condion regarding the System for Award
Management and Unique Enty Idener Requirements in 2 C.F.R. Part 25, Appendix A, the
full text of which is incorporated reference.
Arcle 42
Terminaon of a Federal Award
1) By DHS. DHS may terminate a federal award, in whole or in part, for the following reasons:
a) If the recipient fails to comply with the terms and condi ons of the federal award; (b)
With the consent of the recipient, in which case the par es must agree upon the terminaon
condions, including the effecve date, and in the case of paral terminaon, the poron to
be terminated; or (c) Pursuant to the terms and condions of the federal award, including, to
the extent authorized by law, if the federal award no longer effectuates the program goals or
agency priories. (3) By the Recipient. The recipient may terminate the federal award, in
whole or in part, by sending wrien nocaon to DHS stang the reasons for such
terminaon, the effecve date, and in the case of paral terminaon, the poron to be
terminated. However, if DHS determines that the remaining poron of the federal award will
not accomplish the purposes for which the federal award was made, DHS may terminate the
federal award in its enrety. (4) Noce. Either party will provide wrien noce of intent to
terminate for any reason to the other party no less than 30 calendar days prior to the
effecve date of the terminaon. (5) Compliance with Closeout Requirements for Terminated
Awards. The recipient must connue to comply with closeout requirements in 2 C.F.R. §§
200.344200.345 aer an award is terminated.
Arcle 43
Terrorist Financing
Recipients must comply with Execuve Order 13224 and applicable statutory prohibions on
transacons with, and the provisions of resources and support to, individuals and
organizaons associated with terrorism. Recipients are legally responsible for ensuring
compliance with the Execuve Order and laws.
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Arcle 44
Tra fficking Vicms Protecon Act of 2000(TVPA)
Recipients must comply with the requirements of the government-wide federal award term
and condion which implements Trafficking Vicms Protecon Act of 2000, Pub. L. No. 106-
386, § 106 (codied as amended at 22 U.S.C. § 7104). The federal award term and condion
is in 2 C.F.R. § 175.105, the full text of which is incorporated by reference.
Arcle 45 Uning and Strengthening America by Providing Appropriate Tools Required to Intercept
and Obstruct Terrorism (USA PATRIOT) Act of 2001, Pub. L. 10756
Recipients must comply with the requirements of Pub. L. 107-56, Secon 817 of the USA
PATRIOT Act, which amends 18 U.S.C. §§ 175–175c.
Arcle 46
Use of DHS Seal, Logo and Flags
Recipients must obtain wrien permission from DHS prior to using the DHS seals, logos, crests,
or reproducons of ags, or likenesses of DHS agency officials. This includes use of DHS
component (e.g., FEMA, CISA, etc.) seals, logos, crests, or reproduc ons of ags, or likenesses
of component officials.
Arcle 47
Whistleblower Protecon Act
Recipients must comply with the statutory requirements for whistleblower protecons in 10
U.S.C § 470141 U.S.C. § 4712.
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Arcle 48 Environmental Planning and Historic Preservaon (EHP) Review DHS/FEMA funded
acvies that could have an impact on the environment are subject to the FEMA EHP
review process. This review does not address all federal, state, and local requirements.
Acceptance of federal funding requires the recipient to comply with all federal, state, and
local laws. DHS/FEMA is required to consider the potenal impacts to natural and cultural
resources of all projects funded by DHS/FEMA grant funds, through its EHP review process,
as mandated by: the
Naonal Environmental Policy Act; Endangered Species Act; Naonal Historic
Preservaon Act of 1966, as amended; Clean Water Act; Clean Air Act; Naonal Flood
Insurance Program regulaons; and any other applicable laws, regulaons and execuve
orders. General guidance for FEMA’s EHP process is available on the DHS/FEMA Website.
Specic applicant guidance on how to submit informaon for EHP review depends on the
individual grant program. Applicants should contact their grant Program Officer to be put
into contact with EHP staff responsible for assisng their specic grant program. The FEMA
EHP review process must be completed before funds are released to carry out the proposed
project, otherwise, DHS/FEMA may not be able to fund the project due to noncompliance
with EHP laws, execuve orders, regulaons, and policies. DHS/FEMA may also need to
perform a project closeout review to ensure the applicant complied with all required EHP
condions idened in the inial review. If ground disturbing acvies occur during
construcon, the applicant will monitor the ground disturbance, and if any potenal
archaeological resources are discovered, the applicant will immediately cease work in that
area and nofy the pass-through enty, if applicable, and DHS/FEMA. EO 11988, Floodplain
Management, and EO 11990, Protecon of Wetlands, require that all federal acons in or
affecng the oodplain or wetlands be reviewed for opportunies to relocate, and be
evaluated for social, economic, historical, environmental, legal, and safety consideraons.
FEMA’s regulaons at 44 C.F.R. Part 9 implement the EOs and require an eight-step review
process if a proposed acon is in a oodplain or wetland or has the potenal to affect or be
affected by a oodplain or wetland. The regulaon also requires that the federal agency
provide public noce of the proposed acon at the earliest possible me to provide the
opportunity for public involvement in the decision-making process (44 C.F.R. § 9.8). Where
there is no opportunity to relocate the federal acon, FEMA is required to undertake a
detailed review to determine what measures can be taken to minimize future damages to
the oodplain or wetland.
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Arcle 49
Applicability of DHS Standard Terms and Condions to Tribal Naons The DHS Standard
Terms and Condions are a restatement of general requirements imposed upon recipients
and ow down to sub-recipients as a maer of law, regulaon, or execuve order. If the
requirement does not apply to Tribal Naons, or there is a federal law or regulaon
exempng its applicaon to Tribal Naons, then the acceptance by Tribal Naons, or
acquiescence to DHS Standard Terms and
Condions does not change or alter its inapplicability to a Tribal Naon. The execuon of grant
documents is not intended to change, alter, amend, or impose addional liability or
responsibility upon the Tribal Naons where it does not already exist.
Arcle 50
Acceptance of Post Award Changes
In the event FEMA determines that an error in the award package has been made, or if an
administrave change must be made to the award package, recipients will be noed of the
change in wring. Once the nocaon has been made, any subsequent requests for funds
will indicate recipient acceptance of the changes to the award. Please email FEMA Grant
Management Operaons at: ASK-GMD@fema.dhs.gov for any quesons.
Arcle 51
Disposion of Equipment Acquired Under the Federal Award
When original or replacement equipment acquired under this award is no longer needed for
the original project or program or for other acvies currently or previously supported by a
federal awarding agency, the non-state recipient or subrecipient (including subrecipients of a
State or Tribal Naon), must request instrucons from
FEMA to make proper disposion of the equipment pursuant to 2 C.F.R. secon 200.313(e).
State recipients must follow the disposion requirements in accordance with State laws and
procedures. 2 C.F.R. secon 200.313(b). Tribal Naons must follow the disposion
requirements in accordance with Tribal laws and procedures noted in 2 C.F.R. secon
200.313(b); and if such laws and procedures do not exist, then Tribal Naons must follow the
disposion instrucons in 2 C.F.R. secon 200.313(e).
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Arcle 52 Prior Approval for Modicaon of Approved Budget
Before making any change to the FEMA approved budget for this award, a wrien request
must be submied and approved by FEMA as required by 2 C.F.R. secon 200.308. For
purposes of non-construcon projects, FEMA is ulizing its discreon to impose an addional
restricon under 2 C.F.R. secon 200.308(i) regarding the transfer of funds among direct cost
categories, programs, funcons, or acvies. For awards with an approved budget where the
federal share is greater than the simplied acquision threshold (currently $250,000) and
where the cumulave amount of such transfers exceeds or is expected to exceed ten percent
10%) of the total budget FEMA last approved, transferring funds among direct cost
categories, programs, funcons, or acvies is unallowable without prior wrien approval
from FEMA. For purposes of awards that support both construcon and non-construcon
work, 2 C.F.R. secon 200.308((f)(9) requires the recipient to obtain prior wrien approval
from FEMA before making any fund or budget transfers between the two types of work. Any
deviaons from a FEMA approved budget must be reported in the rst Federal Financial
Report (SF-425) that is submied following any budget deviaon, regardless of whether the
budget deviaon requires prior wrien approval.
Arcle 53
Indirect Cost Rate
2 C.F.R. secon 200.211(b)(16) requires the terms of the award to include the indirect cost rate
for the federal award. If applicable, the indirect cost rate for the award is stated in the budget
documents or other materials approved by FEMA and included in the award le.
Arcle 54
Build America, Buy America Act (BABAA) Required Contract Provision & SelfCercaon
In addion to the DHS Standard Terms & Condions regarding Required Use of American Iron,
Steel, Manufactured Products, and Construcon Materials, recipients and subrecipients of
FEMA nancial assistance for programs that are subject to BABAA must include a Buy America
preference contract provision as noted in 2
C.F.R. secon 184.4 and a self-cercaon as required by the FEMA Buy America
Preference in FEMA Financial Assistance Programs for Infrastructure (FEMA Interim Policy
207-22-0001). This requirement applies to all subawards, contracts, and purchase orders for
work performed, or products supplied under the FEMA award subject to BABAA.
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Arcle 55
Summary Descripon of Award
The purpose of the FY 2026 FWCGP is to enhance security and preparedness for the 2026 FIFA
World Cup events in the United States. This standalone grant program supports the safe
execuon of the largest sporng event in history, co-hosted with Canada and Mexico, which is
expected to aract over ve million internaonal visitors and generate tens of billions of
dollars in economic acvity across 11 U.S. host cies over 38 days. The program addresses
signicant security challenges, with all 78 U.S.based matches designated as Special Event
Assessment Rang (SEAR) I and II events, building on historical federal support for major
events like the Olympics. This FWCGP award consists of funding in the amount of
32,252,845.00. This grant program funds a range of acvies, including planning,
organizaon, equipment purchase, training, exercises, and management and administraon.
Arcle 56 Non-Applicability of Specic Agreement Arcles
Notwithstanding their inclusion in this award package, the following Agreement
Arcles do not apply to this grant award: 1. Communicaon and Cooperaon with the
Department of Homeland Security and Immigraon Officials. 2. Paragraph (2)(a)(iii) of An-
Discriminaon. 3. Terminaon of a Federal Award This provision is consistent with the terms
of the Noce of Funding Opportunity which state that Paragraphs C.IX (Communicaon and
Cooperaon with the Department of Homeland Security and Immigraon Officials),
C.XVII(2)(a)(iii) (An-Discriminaon Grant Award Cercaon regarding immigraon), and
C.XL (Terminaon of a Federal Award) of the FY 2025 DHS Standard Terms and Condions do
not apply to this award.
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Arcle 57
Non-Applicability of Specic Terms and Agreement Arcles Pursuant to County of Santa
Clara, et al. v. Noem, et al.
Pursuant to the preliminary injuncon order issued on November 21, 2025, in County of
Santa Clara et al. v. Noem, et al., No. 25-cv-08330-WHO (N.D. Cal.), the following terms and
condions do not apply to awards or subawards issued to any of the plainffs subject to the
preliminary injuncon order while the order remains in effect: (1) Secon C.XVII of the DHS
Standard Terms and Condions tled "An-
Discriminaon" and the Agreement Arcle tled “An-Discriminaon” in this award package;
and (2) Secon C.XXXI of the DHS Standard Terms and Condions tled
Presidenal Execuve Orders" and the Agreement Arcle tled “Presidenal Execuve
Orders” in this award package. If the preliminary injuncon is stayed, vacated, or
exnguished, Secon C.XVII of the DHS Standard Terms and Condions tled "An-
Discriminaon", the “An-Discriminaon” Agreement Arcle, Secon C.XXXI of the DHS
Standard Terms and Condions tled "Presidenal Execuve Orders," and the Agreement
Arcle tled “Presidenal Execuve Orders” will immediately become effecve. As stated in
the Agreement Arcle tled “NonApplicability of Specic Agreement Arcles, Paragraph
2(a)(iii) of the “AnDiscriminaon” Agreement Arcle and Paragraph 2(a)(iii) of Secon C.XVII
of the DHS Standard Terms and Condions will not apply even if the preliminary injuncon is
stayed, vacated, or exnguished.
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Arcle 58 Non-Applicability of Specic Terms and Agreement Arcles Pursuant to City of Chicago et al.
v. Noem, et al.
Pursuant to the preliminary injuncon order issued on November 21, 2025, in City of Chicago
et al. v. Noem, et al., No. 25-CV-12765 (N.D. Ill.), the following terms and condions do not
apply to awards or subawards issued to any of the plainffs subject to the preliminary
injuncon order while the order remains in effect: (1) Secon C.XVII of the DHS Standard
Terms and Condions tled "An-Discriminaon" and the Agreement Arcle tled “An-
Discriminaon” in this award package; and (2) Secon
C.XXXI of the DHS Standard Terms and Condions tled "Presidenal Execuve Orders" and
the Agreement Arcle tled “Presidenal Execuve Orders” in this award package. If the
preliminary injuncon is stayed, vacated, or exnguished, Secon C.XVII of the DHS Standard
Terms and Condions tled "An-Discriminaon", the “An-Discriminaon” Agreement
Arcle, Secon C.XXXI of the DHS Standard Terms and Condi ons tled "Presidenal Execuve
Orders," and the Agreement Arcle tled “Presidenal Execuve Orders” will immediately
become effecve. As stated in the
Agreement Arcle tled “Non-Applicability of Specic Agreement Arcles, Paragraph
2(a)(iii) of the “An-Discriminaon” Agreement Arcle and Paragraph 2(a)(iii) of Secon C.XVII
of the DHS Standard Terms and Condions will not apply even if the preliminary injuncon is
stayed, vacated, or exnguished.
Arcle 59
Non-Applicability of Specic Terms and Agreement Arcles Pursuant to City of Seale v.
Trump, et al.
Pursuant to the preliminary injuncon order issued on October 31, 2025, in City of Seale v.
Trump, et al., No. 2:25-cv-01435-BJR (W.D. Wa.), the following terms and condions do not
apply to awards or subawards issued to any of the plainffs subject to the preliminary
injuncon order while the order remains in effect: Secon C.XVII of the DHS Standard Terms
and Condions tled "An-Discriminaon" and the
Agreement Arcle tled “An-Discriminaon” in this award package. If the preliminary
injuncon is stayed, vacated, or exnguished, Secon C.XVII of the DHS Standard Terms and
Condions tled "An-Discriminaon" and the “An-Discriminaon”
Agreement Arcle will immediately become effecve. As stated in the Agreement Arcle
tled “Non-Applicability of Specic Agreement Arcles, Paragraph 2(a)(iii) of the “An-
Discriminaon” Agreement Arcle and Paragraph 2(a)(iii) of Secon C.XVII of the DHS
Standard Terms and Condions will not apply even if the preliminary injuncon is stayed,
vacated, or exnguished.
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Arcle 60
Expedited Review of Amendments
For any amendment submied by the Host City Commiee Task Force that requires prior
approval by the State government pass-through enty under 2 CFR part 200, the pass-through
enty must take acon on that request within 10 business days and report the request and
change to FEMA.
Arcle 61
Reducing Pass-Through Time
Notwithstanding the 45 day pass-through requirement in the NOFO, FEMA recognizes the
urgency in which the grant’s stakeholders require access to the funding to enhance the
security and preparedness for the 2026 World Cup events in the United States, the recipient
must pass-through 100% of funds to the Host
Commiee Task Force subrecipients within ten (10) business days aer receipt of the funds in
a manner that is otherwise consistent with the requirements described within the FWCGP
NOFO.
Arcle 62
Prohibion on Covered Foreign Unmanned Aircra Systems (UAS)
As a condion of this award, recipients, subrecipients, and their contractors or subcontractors
must comply with Secon 1825 of the American Security Drone Act of 2023, as enacted in the
Naonal Defense Authorizaon Act for Fiscal Year 2024 (Pub.
L. No. 118-31 §§ 1821-33, 41 U.S.C. 3901 note prec.). Federal funds may not be used to
procure, operate, or otherwise support any covered unmanned aircra system (UAS) that is
manufactured or assembled by a covered foreign enty, or in connecon with the operaon
of such a system. For further guidance, refer to Public Law 118-31 and OMB Memorandum
M-26-02, Ensuring Government Use of Secure Un-manned Aircra Systems and Supporng
United States Producers. Failure to comply with these requirements may result in the
withholding of funds, suspension, or terminaon of the award.
Arcle 63
Award Compliance Hold
Please note that FEMA may reinstate budget or program funding holds if submied
documentaon is incomplete or inconsistent with program requirements. All costs charged to
the federal award remain subject to FEMA review and must comply with the terms and
condions of the award. If issues arise, we will no fy you promptly and work with you to
resolve them.
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ATTACHMENT D
WORK PLAN
FY 2026 FIFA World Cup Grant Program
The purpose of this attachment is to identify the activities planned by the Subrecipient under this Grant
Agreement.
The Subrecipient's approved Work Plan is incorporated herein by reference and attached to this Agreement.
Activities must align with the requirements of the NOFO, the Manual, and the approved application for
funding.
PROJECT DESCRIPTION
PURPOSE and NEED: Explain the overall goal of the project and the specific public safety and security need it addresses. Why is the project
needed?
Project Description – Purpose and Need
The City of Renton’s FIFA World Cup 2026 Public Safety Project is designed to enhance public safety, protect critical infrastructure, and
strengthen emergency preparedness for high-profile international events within the city and surrounding jurisdictions. The overall goal of the
project is to ensure a safe, secure, and coordinated environment for participants, spectators, and staff at two designated venues (team hotel,
practice facility), and transportation corridors during World Cup activities.
This project addresses critical public safety and security needs identified through operational assessments, interagency planning, and planning
with the Seattle FIFA security team. Key challenges include limited staffing capacity to sustain high-visibility operations across multiple venues,
complex communication and coordination requirements across multiple agencies, predictable vulnerabilities during team transportation, and
emerging aerial threats from unmanned aircraft systems (UAS). Without dedicated resources, advanced operational planning, and interagency
coordination, these gaps could increase the risk of incidents and reduce response effectiveness during mass gatherings and high-profile events.
The project is needed to provide dedicated staffing, operational oversight, and advanced capabilities while enhancing interagency
communication, planning, and situational awareness. By addressing these needs proactively, the City of Renton will reduce risk, improve
response times/coverage, strengthen coordination among law enforcement, fire, and emergency management, while ensuring a safe and flexible
operational environment for FIFA World Cup 2026 events.
PLANNED WORK: Describe the activities, services, and/or equipment purchases included.
Planned Work
The project will fund staffing, operational support, planning, and management, and training to enhance public safety for FIFA World Cup 2026
events. Activities include: deployment of dedicated personnel for external security, crowd management, access control, traffic management;
team bus escort operations and training; and coordination with police and emergency management for unified command and situational
awareness during World Cup operations.
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OUTCOME
Outcome – Enhancing Response to FIFA World Cup 2026 Threats
The City of Renton’s project strengthens its ability to prevent, prepare for, and respond to potential threats during FIFA World Cup 2026 events
through expanded staffing, operational coverage, and enhanced capabilities by training personnel for vehicle escorts. By addressing gaps in
staffing, communication, pre-planning, and coordination identified through operational assessments and the City of Renton’s October 2025 full-
scale World Cup Exercise, the project ensures a proactive, unified, and effective public safety response.
Expected Outcomes and Operational Enhancements:
Rapid, Unied Response:
oDedicated staffing for external security, crowd control, access control, traffic management, and team escorts
oImproved coordinaon among police, re, and Emergency Management to reduce response mes and streamline incident management
Expanded Coverage:
oConnuous operaonal oversight at two venues, team hotels, pracce facilies, and key transportaon routes
oComprehensive monitoring for crowd management, general security, and safe transport of team
Enhanced Operaonal Capabilies:
oUAS detecon and aerial overwatch for emerging aerial threats
oStructured pre-planning and lessons learned from prior exercises to reduce reaconary response and increase situaonal awareness
Improved Communicaon and Coordinaon:
oReal-me informaon sharing and command-and-control across all parcipang agencies
oStrengthened operaonal protocols (coordinaon, communicaons, situaonal assessment)
oOperaons: RPD command staff member and emergency management liaison staff member dedicated to World Cup operaons for planning
and management purposes through regional events
These enhancements directly align with FIFA World Cup 2026 Safety and Security Planning Lines of Effort, ensuring Renton meets standards for
Emergency Preparedness, Intelligence & Threat Analysis, Physical Security & Access Control, Crowd Management, Transport Security & Escorts,
and Crisis Management & Tactical Coordination. The project increases organizational readiness, mitigates risk, and ensures safe and secure
operations for participants, spectators, and the broader community.
Explain how the project will improve your organization's ability to respond to threats related to the FIFA World Cup 2026 games. Include
expected performance improvements, coverage expansion, and/or operational enhancements.
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ATTACHMENT E
TIMELINE
FY 2026 FIFA World Cup Grant Program
The purpose of this attachment is to identify applicable and agreed upon due dates for Grant Agreement
milestones to include deliverables that must be submitted to the Organization. Both the Organization and the
Subrecipient shall monitor adherence with the dates below.
The Subrecipient must request prior written approval from Organization Key Personnel to waive or extend
the due date in the above Timeline.
For waived or extended reimbursement due dates, all allowable costs should be submitted on the next
scheduled reimbursement submission due date contained in the above Timeline.
PROJECT SCHEDULE
MILESTONE START DATE END DATE
6/8/2026 7/8/2026
6/8/2026 7/8/2026
4/1/2026 6/2/2026
6/8/2026 7/8/2026
6/8/2026 7/8/2026
7/8/2026PROJECTCOMPLETION (no later than 8/31/2026)
Planning and Management
Project / Grant Management
PROJECT START (no earlier than 7/4/2025)
Venue security (Hyatt Hotel and Longacres/Seattle Sounders FC practice facility
Transports - vehicle escorts, team movemement
Training - vehicle escort training
INSTRUCTIONS: Enter the major milestones for the project. Please include at least 2 milestones.
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ATTACHMENT F
BUDGET
FY 2026 FIFA World Cup Grant Program
The purpose of this attachment is to identify how the funding is budgeted for the identified activities in the
Work Plan. If funding is identified as not being required, contact the Organization Key Personnel as soon as
possible so funding can be reallocated.
PLANNING ORGANIZATION EQUIPMENT TRAINING EXERCISE M&A TOTAL
Salaries & Benefits 22,095$ 332,751$ 20,950$ 375,797$
Supplies -$
Travel/Per Diem -$
Contractor/Consultant -$
Other 2,616$ 2,616$
Equipment -$
SUBTOTAL 22,095$ 332,751$ -$ 20,950$ -$ 2,616$
Indirect
TOTAL 378,412$
AGREEMENT AMOUNT $378,412
PROJECT BUDGET
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ATTACHMENT G
BUILD AMERICA, BUY AMERICA ACT SELF-CERTIFICATION
The undersigned certifies, to the best of their knowledge and belief, that:
The Build America, Buy America Act (BABAA) requires that no federal financial assistance for "infrastructure"
projects is provided "unless all of the iron, steel, manufactured products, and construction materials used in
the project are produced in the United States." Section 70914 of Public Law No. 117-58, §§ 70901-52.
The undersigned certifies that for the _____________________ [Insert Project Name and Location] that the
iron, steel, manufactured products, and construction materials used in this contract are in full compliance
with the BABAA requirements including:
1. All iron and steel used in the project are produced in the United States. This means all
manufacturing processes, from the initial melting stage through the application of coatings, occurred
in the United States.
2. All manufactured products purchased with FEMA financial assistance must be produced in the
United States. For a manufactured product to be considered produced in the United States, the cost
of the components that are mined, produced, or manufactured in the United States is greater than
55% of the total cost of all components.
3. All construction materials are manufactured in the United States. This means that all
manufacturing processes for the construction material occurred in the United States.
The [Contractor or Subcontractor], ________________________, certifies or affirms the truthfulness and
accuracy of each statement of its certification and disclosure, if any. In addition, the [Contractor or
Subcontractor] understands and agrees that the provisions of 31 U.S.C. Chap. 38, Administrative Remedies
for False Claims and Statements, apply to this certification and disclosure, if any."
Signature of [Contractor's or Subcontractor's] Authorized Official
Name and Title of [Contractor's or Subcontractor's] Authorized Official
Date
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