In a separate, but related action, the Department of Defense amended the Federal Acquisition Regulation (“FAR”) to implement the ISA. The new regulation requires government contractors and prospective government contractors to certify that neither they nor any entity owned or controlled by them is engaged in activity sanctionable under the ISA. The certification requirement applies to all procurement contracts with the U.S. government. False certifications could lead to contract termination, contractor suspension, or debarment of the contractor for up to three years. There is an exception for the procurement of eligible products, as defined under the Trade Agreements Act (the “Act”), from a country designated under the Act.