FAR 52.204-24

Representation Regarding Certain Telecommunications and Video Surveillance Services or Equipment

Per FAR 52.204-24,  (d) Representation. Hak5 LLC, the Offeror represents that—

(1) It will not provide covered telecommunications equipment or services to the Government in the performance of any contract, subcontract or other contractual instrument resulting from this solicitation. The Offeror shall provide the additional disclosure information required at paragraph (e)(1) of this section if the Offeror responds "will" in paragraph (d)(1) of this section; and

(2) After conducting a reasonable inquiry, for purposes of this representation, the Offeror represents that—

It does not use covered telecommunications equipment or services, or use any equipment, system, or service that uses covered telecommunications equipment or services. The Offeror shall provide the additional disclosure information required at paragraph (e)(2) of this section if the Offeror responds "does" in paragraph (d)(2) of this section.


NDAA 889(a)(1)(B)

Prohibition on Contracting With Entities Using Certain Telecommunications and Video Surveillance Services or Equipment (FAR Case 2019-009)

Hak5 LLC product(s) in are not manufactured by, contain components manufactured by, or receive substantial influence from entities prohibited by Section 889 of the 2019 NDAA. These entities include the following companies and any of their subsidiaries or affiliates:

  • Hytera Communications Corporation
  • Huawei Technologies Company
  • ZTE Corporation
  • Dahua Technology Company
  • Hangzhou Hikvision Digital Technology Company


TAA Compliance & Country of Origin

Hak5 LLC software products (available from are designed and tested in the United States, with development occurring in both the United States and United Kingdom. This includes all firmware for information processing devices, utilities, encoders, and server application software (Cloud C2).

Hak5 LLC hardware products (also known as "Hak5 Gear", as listed at are designed and tested in the United States, with manufacturing and assembly occuring in the People's Republic of China.

Non-US-Made End Products

The End Product Country of Origin depends on where the final programming, or substantial transformation, occurs.

Some "Hak5 Gear" products are assembled in China using software designed, developed and tested in the United States and United Kingdom. The following products are not US made end products, as the final substantial transformation (programming) occurs in China:

  • USB Rubber Ducky
  • Bash Bunny
  • LAN Turtle
  • Packet Squirrel
  • Shark Jack
  • Plunder Bug
  • Key Croc
  • Screen Crab.


US-Made End Products

Some "Hak5 Gear" products are assembled in China using "blank" configuration software designed, developed and tested in the United States and United Kingdom. The following products are US-Made End Products, as the final substantial transformation (programming) may occur in the US with the US/UK designed, tested and developed software as provided by servers residing in the US:

  • WiFi Pineapple


Country of Origin Guide

Product Name Software
Final Assembly
(Substantial Transformation)
of Origin
US Assembly Option*
Cloud C2 US n/a n/a US n/a
WiFi Pineapple US CN US (Customer Origin) US Y
USB Rubber Ducky US CN CN CN Y
Bash Bunny US CN CN CN Y
Packet Squirrel US CN CN CN Y
Plunder Bug US CN CN CN N
Signal Owl US CN CN CN Y
Screen Crab US CN CN CN N
Shark Jack US CN CN CN Y
Key Croc US CN CN CN Y

 * These products may be optionally programmed in the US, if TAA compliance is required.


Authorized Resellers

All Hak5 LLC authorized resellers are subject to the terms of service and compliance rules set forth in these policies

Europe Firewire Revolution
Europe HackmoD
Europe Lab401
United Kingdom FoneFunShop



Export Compliance

Exports, re-exports and transfers of Hak5 products and technology are subject to control under the Export Administration Regulations ("EAR"), as administered by the U.S. Department of Commerce's Bureau of Industry and Security ("BIS"). Diversion of Hak5 products and technology contrary to U.S. law is prohibited. Depending on where you reside, additional import or export requirements may apply.

The export or re-export of items that are subject to the EAR to an embargoed or sanctioned destination (Cuba, Iran, North Korea, Sudan, and Syria) without a valid license or license exception is prohibited. Further, the U.S. Department of Treasury's Office of Foreign Assets Control may impose additional controls on exports, re-exports, or transfers to these destinations.

Exports to entities listed on a U.S. government denied party/prohibited end-user list may be prohibited or proceed only if they have been licensed. Further information on these lists may be found here. In addition, exports that support the design, development, or production of biological, chemical, or nuclear weapons, or missile proliferation, are prohibited without prior U.S. government authorization.

Please note that the information set forth on this web page is provided for general reference purposes only. It is not intended to constitute legal guidance, and the information contained herein is subject to change at any time by the BIS or other U.S. government authorities. Please consult the EAR, or contact the BIS, for further details on U.S. export control and licensing requirements.

Product Export Classification and Licensing Definitions

Following are definitions of key terms that relate to the export classification and licensing of Hak5 products and technology. If you have a question about how an Hak5 product has been classified for export, please refer to the Export Product Classification Guide or contact our Export Compliance team at

ECCN: The Export Control Classification Number, or ECCN, is the U.S. term for an export classification code. An ECCN identifies the relevant category and paragraph of a classification, as they are maintained under the EAR's Commerce Control List.

Typically, Hak5 products are classified under one of the following ECCNs:

5A992(c): Equipment not controlled by 5A002. (c) – Commodities classified Mass Market – 740.17(b)

5D992(c): Software that has the characteristics, or performs or simulates the functions of the equipment controlled by ECCN 5A992(a), but which does not meet the characteristics of ECCN 5A002.

License Exception: A license exception is an authorization that allows the export or re-export of items subject to the EAR without first obtaining an export license under certain specified conditions. Most Hak5 products may be exported under License Exception ENC, as set forth under Section 740.17 of the EAR.

ENC-Unrestricted: Refers to products that may be exported or re-exported under License Exception ENC to government or non-government end users in all countries, except embargoed or sanctioned countries.

Mass-Market Encryption: Refers to products that meet the following characteristics:

  1. Generally available to the public by being sold, without restriction, from stock at retail selling points by means of any of the following:
    1. Over-the-counter transactions;
    2. Mail order transactions;
    3. Electronic transactions (e.g., Internet); or
    4. Telephone call transactions.
  2. The cryptographic functionality cannot be easily changed by the user;
  3. Designed for installation by the user without further substantial support by the supplier; and
  4. When necessary, details of the items are accessible and will be provided, upon request, to the appropriate authority in the exporter's country in order to ascertain compliance with the conditions described in paragraphs (a) through (c).

ENC Reporting: Refers to the annual reporting requirement, as set forth under the Section 740.17(b)(1) of the EAR, for exports to all destinations other than Canada, and for re-exports from Canada for certain encryption items.


Export Product Classification Guide

Product Description



Eligible License Exception

Encryption Status



Hak5 Cloud C2

5D992.c NLR





WiFi Pineapple

MK7: 811342030651
TETRA: 811342030064
NANO: 811342030057

5A992.c NLR





USB Rubber Ducky


5A992.c NLR





LAN Turtle


5A992.c NLR





Bash Bunny


5A992.c NLR





Packet Squirrel


5A992.c NLR





Plunder Bug 811342030545

5A992.c NLR

Signal Owl 811342030514

5A992.c NLR

Screen Crab 811342030552

5A992.c NLR

Shark Jack 811342030576

5A992.c NLR

Key Croc 811342030569

5A992.c NLR




Hak5 LLC products and technology are only available to BIS recognized license exception ENC favorable treatment countries pursuant to US 15 CFR Supplement No 3 to Part 740.

  • Austria
  • Australia
  • Belgium
  • Bulgaria
  • Canada
  • Croatia
  • Cyprus
  • Czech Republic
  • Estonia
  • Denmark
  • Finland
  • France
  • Germany
  • Greece
  • Hungary
  • Iceland
  • Ireland
  • Italy
  • Japan
  • Latvia
  • Lithuania
  • Luxembourg
  • Malta
  • Netherlands
  • New Zealand
  • Norway
  • Poland
  • Portugal
  • Romania
  • Slovakia
  • Slovenia
  • Spain
  • Sweden
  • Switzerland
  • Turkey
  • United Kingdom
  • United States

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