US. Department of Justice Of?ce of Legislative Affairs Of?ce of the Assistant Attorney General Washington, D. C. 20530 July 7, 2016 The Honorable John A. Culberson Chairman Subcommittee on Commerce, Justice, Science and Related Agencies Committee on ApprOpriations US. House of Representatives Washington, DC 20515 Dear Mr. Chairman: This supplements the Department of Justice?s (the Department) March 18, 2016, letter to you regarding compliance with applicable federal law by certain Department grantees. At that time, we noti?ed you that we had been in contact with the Department?s Inspector General (1G) to discuss compliance with 8 U.S.C. 1373 (Section 1373) and the relationship to our grant/reimbursement programs. We made clear that we shared your February 26, 2016, correspondence with the IG and planned to work with him as appropriate to enable his review of grantee compliance with Section 1373. As you know, the Department subsequently provided the IG information necessary for him to conduct his review, and on May 31, 2016, the 1G provided a memorandum to the Department describing the results of his review Memorandum?). On July 7, 2016, the Department responded to the IG. A copy of this response is enclosed for your reference. In addition to providing information to the IG, in our correspondence of March 18, 2016, we also told you that we would emphasize to prospective applicants the importance and requirement of adherence to all applicable federal laws under the FY 2016 Edward Byrne Justice Assistance Grant (JAG) Program and State Criminal Alien Assistance Program (SCAAP). Consistent with our commitment to you and the recommendations received from the IG, on July 7, 2016, the Department?s Of?ce of Justice Programs (OJP)?which has determined that Section 1373 is an applicable federal law for the purposes of JAG and provided the enclosed guidance on the requirements of Section 1373 to all such recipients, including but not limited to those jurisdictions identi?ed in the IG Memorandum. To ensure that grantees comply with Section 1373 and all other applicable federal law, OJP already requires all grant applicants electronically to acknowledge and accept the conditions contained in two documents? ?General Assurances? and ?General Certi?cations??as preconditions to a grant award. The General Assurances document (enclosed) currently states: ?The applicant hereby assures and certi?es compliance with all applicable Federal The Honorable John A. Culberson Page Two statutes, regulations, policies, guidelines, and requirements These assurances and certi?cations are required for participation in the SCAAP repayment program as well. In addition to clarifying the meaning of Section 1373, the guidance includes reSponses to other questions received from Bureau of Justice Assistance grantees regarding compliance with Section 1373. Additionally, OJP has requested that recipients ensure that the Department?s guidance is clearly communicated to their personnel and subrecipients, as well as other relevant partners and/or other entities. We believe that these steps will help ensure that recipients are complying with Section 1373. We hope this information is helpful. Please do not hesitate to contact this of?ce if we may provide additional assistance regarding this or any other matter. Sincerely, Peter J. Kadzik Assistant Attorney General Enclosures cc: The Honorable Mike Honda Acting Ranking Member US. Department of Justice Of?ce of Justice Programs Office of the Assistant Attorney General Washington, 2053} July 7, 2016 MEMORANDUM TO: Michael Horowitz Inspector General US. Department of Justice FROM: Karol V. Mason Assistant Attorney General Of?ce of Justice Programs SUBJECT: Response: Department of Justice Referral of Allegations of Potential Violations of 8 U.S.C. 6 1373 by Grant Recipients We appreciate the review undertaken by the Department of Justice (D01 or the Department), Of?ce of the InSpector General (01G) regarding compliance with 8 U.S.C. 1373 (Section 1373) by the Department?s grant recipients. In conducting this review, 016 selected 10 state and local jurisdictions for further review. For these jurisdictions, OIG researched the local laws and policies that govern their interactions with US. Immigration and Customs Enforcement (ICE) and compared these local laws and policies with Section 1373. DIG then provided this report to the Department to assist the Department in determining the appropriate next steps to ensure compliance with Section 1373. The Of?ce of Justice Programs (OJP) has determined that Section 1373 is an applicable federal law for the purposes of the Edward Byrne Memorial Justice Assistance Grant (JAG) program and the State Criminal Alien Assistance Program (SCAAP). To ensure that grantees comply with Section 1373, OJP has provided the attached guidance to all JAG and SCAAP grantees. Notably, this guidance provides grantees and applicants with clear direction on the requirements of Section 1373: Title 8, United States Code, Section 1373 addresses the exchange of information regarding citizenship and immigration status among federal, state, and local government entities and of?cials. Subsection prevents federal, state and local government entities and of?cials from ?prohibit[ing] or in any way restrict[ing]? government of?cials or entities ?'om sending to, or receiving from, federal immigration of?cers information concerning an individual? 3 citizenship or immigration status. Subsection provides that no person or agency may ?prohibit, or in any way resn'ict,? a federal, state, or local government entity from (1) sending to, or requesting or receiving from, federal immigration of?cers information regarding an individual?s inandgration status, (2) maintaMng such information, or (3) exchanging such information with any other federal, state, or local government entity. Section 1333 does not impose, on states and localities the affirmative obligation to collect information item private individuals regarding their immigration status, nor does it require that states and localities take speci?c actions upon obtaining such infomation. Rather, the statute prohibits government entities and omcials from taking action to prohibit or in any way restrict the maintenance or intergovernmental exchange of such information, including through written or unwritten policies or practices. To ensure that grantees comply with Section 1373 and all other applicable federal law, 01? already requires all applicants for any grant program electronically to acknowledge and accept the conditions contained in two attached documents titled ?Standard Assurances? and ?Certifications Regarding Lobbying; Debannent, Suspension and Other Responsibility Matters; and Drug-Free Workplace Requiremen as preconditions to a grant award. The Standard Assurances document currently states: ?The applicant hereby assures and certi?es compliance with all applicable Federal statutes, regulations, policies, guidelines, and requirements . These assurances and certi?cations are required for participation in the SCAAP repayment program as well. Accompanying this letter are in reSponse to questions received from Bureau of Justice Assistance grantees regarding compliance with Section 1373. Additionally, OJP has requested that grantees ensure that the Department?s guidance is clearly communicated to their personnel and subrecipients, as well as other relevant partners andfor other entities. We believe that these steps will help ensure that grantees are complying with Section 1373. Attachments cc: The Honorable Peter J. Kadzik Assistant Attomey General Office of Legislative A?airs OFFICE OF JUSTICE PROGRAMS GUIDANCE REGARDING WITHS U.S.C. ?1373 1. Q. one: does a use. 13:73 require? A. Title 8, United States Code, Section 1373 (Section 1373) addresses the exchange of information regarding citizenship and immigration status among federal, state, and local government entities and of?cials. Subsection prevents federal, state and local government entities and officials from ?prohibit[ing] or in any way government of?cials or entities ?om sending to, or receiving from, federal immigration of?cers infonnation concerning an individual?s citizenship or immigration status. Subsection provides that no person or agency may ?prohibit, or in any way restrict,?I a federal, state, or local government entity from (1) sending to, or requesting or receiving ?ora, federal immigration officers information regarding an individual?s immigration status, (2) maintaining such information, or (3) exchanging such information with any other federal, state, or local govermnent entity. Section 1373 does not impose on states and localities the af?rmative obligation to collect information from private individuals regarding their immigration status, nor does it require that states and localities take actions upon obtaining such information. Rather, the statute prohibits entities and o?icials from taking action to prohibit or in any way restrict the maintenance or intergovernmental exchange of such infonnation, including through written or unwritten policies or practices. Your personnel must be informed that notwithstanding any state or local policies to the contrary, federal law does not allow any government entity or of?cial to prohibit the sending or receiving of information about an individual?s citizenship or immigration status with any federal, state or local government entity and o?i'cials. 2. Q. May a state make a subgrant to a city that the state knows to be violating an applicable law or regulation (cg. Section 13 or a requirement? A. No. A JAG grantee is required to assure and certify compliance with all applicable federal statues, including Section 1373, as well as all applicable federal regulations, policies, guidelines and requirements. This requirement passes through to any that may be made and to any that receive ?mds under the grant. 3. Q. Is there a speci?c report or source BJA is using to determine whether afar-irritation has violated an applicable Federal law (cg. Section 1373)? A. The Of?ce of Justice Programs (OJP) will take seriously credible evidence of a violation of applicable Federal law, including a violation of Section 1373, ?orn any source. In the ordinary course, OJP will refer such evidence to the of Justice?s Of?ce of the Inspector General for appropriate action. Q. How would a determination that a subgrentee is in violation affedera! law afoot the state?s designation and ability to recaivefuture awards? A. A grantee is responsible to the federal government for the duration of the award. As the primary recipient of the award, the grantee is responsible for ensuring that assure and certify compliance with federal program and grant requirements, laws, or regulations (ag. Section 1373). If a grantee or subgrantee has policies or practices in effect that violate Section 1373, the grantee or subgrantee will be given a reasonable amount of time to remedy or clarify such policies to ensure compliance with applicable law. Failure to remedy any violations could result in the withholding of grant funds or ineligibility for future grants or subgrants, or other adn?nistrative, civil, or criminal penalties, as appropriate. Our goal is to ensure that JAG grantees and subgrantees are in compliance with all applicable laws and regulations, including Section 1373, not to withhold vitally important criminal justice funding from states and localities. 5. Q. Does the Sanctum Policy Guidance? notice apply to all active grants? A. The Policy Guidance applies to all JAG grantees and subgrantees. 6. Q. What shoutd a. state be doing to ensure that subgronrees are complying with the legs! requirementsfor receiving IA Gfunds? A. The state must comply with all of the requirements of 2 C.F.R. 200.331. See also Section 3.14 (Subrecipient Monitoring) of the Department of Justice Financial Guide. 7. Q. The Sanctuary Policy Guidance? cited Section 13 73. Are there other components of Title 3 ofthe United States Code that are required for compliance? A. All grantees are required to assure and certify compliance with all applicable federal statutes, regulations, policies, guidelines, and requirements. States may wish to consult with their legal counsel if they have any questions or concerns as to the scope of this requirement. 6. It will comply (and will require any subrecipients or contractors to comply) with any applicable 7. Ifa governmental entity-? no. EXPIRES sci/2019 STANDARD ASSURANCES The Applicant hereby assures and certi?es compliance with all applicable Federal stahrtes, regulations, policies, guidelines, and requirements, including 2 C.F.R. Part 2800 (Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards by the Deparhnent oflustice), and Ex. Order 12372 (intergovernmental review of federal programs). The applicant also specifically assures and certi?es that: 1. It has the legal authority to apply for federal assistance and the institutional, managerial, and ?nancial capability (including funds suf?cient to pay any required non-federal share of project cost) to ensure proper planning, management, and completion of the project described in this application. 2. It will establish safeguards to prohibit employees from using their positions for a purpose that constitutes or presents the appearance of personal or organizational con?ict of interest, or personal gain. 3. It will give the awarding agency or the Government Accountability O?ce, through any authorized representative, access to and the right to examine all paper or electronic records related to the ?nancial assistance. 4. It will comply with all lawful requirements imposed by the awarding agency, speci?cally including any applicable regulations, such as 28 C.F.R. pts. 18, 22, 23, 30, 35, 38, 42, 61, and 63, and the award term in 2 C.F.R. 5. It will assist the awarding agency (if necessary) in assuring compliance with section 106 of the National Historic Preservation Act of 1966 (16 U.S.C. 470), For. Order I 1593 (identi?cation and pmteetion of historic properties), the Archeological and Historical Preservation Act of I974 (16 U.S.C. 469a?1 et seq), and the National Environmental Policy Act of 1969 (42 U.S.C. 4321). nondiscrimination provisions, which may irrolude the Omnibus Crime Control and Safe Streets Act of 1968 (42 U.S.C. 378%); the Victims of Crime Act (42 U.S.C. ?10604(e)); the Juvenile Justice and Delinquency Prevention Act of 2002 (42 U.S.C. 5672Cb)); the Violence Against Women Act (42 U.S.C. l3925(b)(13)); the Civil Rights Act of 1964 (42 U.S.C. 2000(1); the Indian Civil Rights Act (25 U.S.C. 1301?1303); the Rehabilitation Act of 1973 (29 U.S.C. 794); the Americans with Disabilities Act of 1990 (42 U.S.C. 12131- 34); the Education Amendments of 1972 (20 U.S.C. 1681, 1683, 1685-86); and the Age Discrimination Act of I 1975 (42 U.S.C. 6101-07). It will also comply with Ex. Order 13279, Equal Protection of the Laws for Faith? . Based and Community Organizations; Executive Order 13559, Fundamental Principles and Policymaking Criteria for Partnerships With Faith-Based and Other Neighborhood Organizations; and the DOJ implementing regulations at 28 C.F.R. Part 38. a) it will comply with the requirements of the Uniform Relocation Assistance and Real Property Acquisitions Act of 1970 (42 460] et seq), which govern the treatment of persons displaced as a result of federal and federally~assisted programs; and b) it will comply with requirements of 5 1501-08 and ??73 24?28, which limit certain political activities of State or local government employees whose principal employment is in connection with an activity ?nanced in whole or in part by federal assistance. Page 1 of 3 US. DEPARTMENT OF JUSTICE OFFICE OF JUSTICE PROGRAMS OFFICE OF THE CHIEF FINANCIAL OFFICER CERTIFICATIONS REGARDING DEBARMENT, SUSPENSION AND OTHER RESPONSIBILITY AND WORKPLACE REQUIREMENTS Applicants should refer to the regulations cited below to determine the certi?cation to which they are required to attest. Applicants should also review the instructions for certi?cation included in the regulations before cornpleting this form. Acceptance of this form provides for compliance with certi?cation requirements under 28 Part 89. "New Restrictions on Lobbying." 2 CFR Part 2867, "00.1 implementation of OMB Guidance on Nonprocurernent Debarment and Suspension." and 23 CFR Part 83. ?Government-wide Debarment and Suspension," and Government?wide Requirements for Drug-Free Workplace (Grants}." The certifications shall be treated as a material representation of fact upon which reliance will be placed when the Departmant of Justice determines to award the covered transaction. grant. or cooperative agreement. 1. LOBBYING As required by Section 1352, Title 31 of the U.S. Code. and implemented at 23 CFR Part 69. for persons entering into a grant or cooperative agreement over $100,000, as de?ned at 28 Part 69. the applicant certifies that: No Federal appropriated funds have been paid or will be paid. by or on behalf of the undersigned, to any person for in?uencing or attempting to in?uence 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 connection with the making of any Federal grant, the entering into of any cooperative agreement, and the extension. continuation, renewal. amendment. or modi?cation of any Federal grant or cooperative agreement; if any funds other than Federal appropriated funds have been paid or will be paid to any person for in?uencing or attempting to influence an of?cer or employee of any agency. a Member of Congress, an officer or employee of Congress. or an employee of a Member of Congress in connection with this Federal grant or cooperative agreement, the undersigned shall complete and submit Standard Form - ?Disclosure of Lobbying Activities," in accordance with its instructions; The undersigned shalt require that the language of this certi?cation be included in the award documents for all subawards at all tiers (including subgrants. contracts under grants and cooperative agreements, and subcontracts) and that all sub-recipients shall certify and disclose accordingly. 2. DEBARMENT, SUSPENSION. AND OTHER MATTERS (DIRECT Pursuant to Executive Order 12549. Debarment and Suspension. implemented at 2 OF Part 286?. for prospective participants in primary covered transactions. as defined at 2 CFR Section and other requirements: A. The applicant certi?es that it and its principals: Are not presently deberred, suspended, proposed for debarrnent. declared ineligible, sentenced to a denial of Federal bene?ts by a State or Federal court. or votu ntarily excluded from covered transactions by any Federal department or agency; (in) Have not within a three-year period preceding this application been convicted of or had a civil judgment rendered against them for commission of fraud or a criminal offense in connection with obtaining. attempting to obtain. or perionning a public (Federal. State, or local} transaction or contract under a public transaction; violation of Federal or State antitrust statutes or commission of embezzlement, theft. forgery. bribery, falsification or destruction of records. making false statements, or receiving stolen property; Have not within a two-year period preceding this application been convicted of a felony criminal violation under any Federal law. unless such felony criminal conviction has been disclosed in writing to the Of?ce of Justice Programs (OJP) at and, after such disclosure. the applicant has Page 2 of 3 received a specific written determination from OJP that neither suspension nor debannent of the applicant is necessary to protect the interests of the Government in this case. Are not presentiy indicted for or otherwise criminally or civilly charged by a governmental entity (Federal. State. or local) with commission of any of the offenses enumerated in paragraph of this codification; and Have not within a three?year period preceding this application had one or more public transactions (Federai. State. or local} terminated for cause or default. B. Where the applicant is unable to certify to any of the statements in this certi?cation. he orshe shall attach an explanation to this application. 3. FEDERAL TAXES A. If the applicant is a corporation. the applicant certi?es that either (1) the corporation has no unpaid Fedora! tax liability that has been assessed. for which all judiciai and administrative remedies have been exhausted or have lapsed, that is not being paid in a timely manner pursuant to an agreement with the authority responsible for coiiecting the tax liability. or (2) the corporation has provided written notice of such an unpaid tax liability (or liabilities) to OJP at and. after such disciosure, the applicant has received a specific mitten determination from 0.1? that neither suspension nor deberment of the applicant is necessary to protect the interests of the Government in this case. B. Where the applicant is unable to certify to any of the statements in this certi?cation. he or she shall attach an explanation to this application. 4. DRUG-FREE WORKPLACE (GRANTEES OTHER THAN INDNIDUALS) As required by the Drug-Free Workplace Act of 1988. and implemented at 28 CFR Part 83. Subpart F. for grantees. as de?ned at 28 CFR Sections 83.620'and 83.650: A. The applicant certi?es that it will or will continue to provide a drug~free workpiece by: Publishing a statement notifying employees that the unlawful manufacture. distribution, dispensing. possession. or use of a controlled substance is prohibited in the grantee's workplace and specifying the actions that will be taken against employees for violation of such prohibition; . Establishing an on-going drug-tree awareness program to inform employees about (1) The dangers of drug abuse in the workplace; (2) The grantee?s policy of maintaining a drug-free workpiece; Any avaitabie drug counseling. and empioyee assistance programs; and (4) The penalties that may be imposed upon employees for drug abuse violations occurring in the workplace; Making it a requirement that each employee to be engaged in the performance of the grant be given a copy of the statement required by paragraph Notifying the employee in the statement required by paragraph that, as a condition of employment under the grant. the employee will Abide by the terms of the statement; and Notify the employer in writing of his or her conviction for a violation of a criminal drug statute occurring in the workpiece no later than ?ve calendar days after such conviction; Notifying the agency. in writing. within 10 calendar days after receiving notice under sobparagreph from an employee or otherwise receiving actual notice of such conviction. Employers of convicted employees must provide notice. inciuding position title. to: Department of Justice. Office of Justice Programs, Page3of3 Control Desk, 810 'i?th Street, N.W., Washington, 0.6. 20531. Notice shall include the identification number(s) of each affected grant: Taking one of the following actions, within 30 calendar days of receiving noticeundar suhparagraph with respect to any employee who is so convicted Taking appropriate personnel aotioo against such an employee, up to and including termination, consistent with the requirements of the Rehabilitation Act of 191%! as amended; or Requiring such employee to participate satisfactorily in a drag abuse assistance or rehabilitation program approved for such purposes by a Federal, State, or local heatth, law enforcement. or other appropriate agency: Making a good faith effort to continue to maintain a drug?free workplace through implementation at Paragraphs (8). (C), id), and As the duly authorized representative of the applicant, I hereby certify that the applicant will comply with the above certi?cations. OFFICE OF JUSTICE PROGRAMS GUIDANCEREGARDING COMPLIANCE WITHS U.S.C. 1373 I. Q. What does 8 U.S.C. 13 73 require? A. Title 8, United States Code, Section 1373 (Section 1373) addresses the exchange of information regarding citizenship and immigration status among federal, state, and local goverinnent entities and of?cials. Subsection prevents federal, state and local government entities and officials from ?prohibit[ing] or in any way restrict[ing]? government officials or entities from sending to, or receiving from, federal immigration of?cers information concerning an individual?s citizenship or immigration status. Subsection provides that no person or agency may ?prohibit, or in any way restrict,? a federal, state, or local government entity from (1) sending to, or requesting or receiving from, federal immigration of?cers information regarding an individual?s immigration status, (2) maintaining such information, or (3) exchanging such information with any other federal, state, or local government entity. Section 1373 does not impose on states and localities the af?rmative obligation to collect information from private individuals regarding their immigration status, nor does it require that states and localities take speci?c actions upon obtaining such information. Rather, the statute prohibits government entities and of?cials from taking action to prohibit or in any way restrict the maintenance or intergovernmental exchange of such information, including through written or unwritten policies or practices. Your personnel must be informed that notwithstanding any state or local policies to the contrary, federal law does not allow any government entity or official to prohibit the sending or receiving of information about an individual?s citizenship or immigration status with any federal, state or local government entity and of?cials. 2. Q. May a state make a sabgrant to a city that the state knows to be violating an applicable law or regulation g. Section 13 73), or a programmatic requirement? A. No. A JAG grantee is required to assure and certify compliance with all applicable federal statues, including Section 1373, as well as all applicable federal regulations, policies, guidelines and requirements. This requirement passes through to any subgrants that may be made and to any that receive funds under the grant. 3. Q. Is there a specific report or source BJA is using to determine whether a jurisdiction has violated an applicable Federal law g. Section 13 73)? A. The Office of Justice Programs (OJP) will take seriously credible evidence of a violation of applicable Federal law, including a violation of Section 1373, from any source. In the ordinary course, OJP will refer such evidence to the Department of Justice?s Office of the Inspector General for appr0priate action. 4. Q. How would a determination that a subgrantee is in violation of federal law affect the state ?s designation and ability to receive future awards? A. A grantee is responsible to the federal government for the duration of the award. As the primary recipient of the award, the grantee is responsible for ensuring that subgrantees assure and certify compliance with federal program and grant requirements, laws, or regulations g. Section 1373). If a grantee or subgrantee has policies or practices in effect that violate Section 1373, the grantee or subgrantee will be given a reasonable amount of time to remedy or clarify such policies to ensure compliance with applicable law. Failure to remedy any violations could result in the withholding of grant funds or ineligibility for future OJP grants or subgrants, or other administrative, civil, or criminal penalties, as appropriate. Our goal is to ensure that JAG grantees and subgrantees are in compliance with all applicable laws and regulations, including Section 1373, not to withhold vitally important criminal justice ?mding from states and localities. 5. Q. Does the Sanctuary Policy Guidance? notice apply to all active grants? A. The Policy Guidance applies to all JAG grantees and subgrantees. 6. Q. What should a state he doing to ensure that are complying with the legal requirements for receiving JA funds? A. The state must comply with all of the requirements of 2 C.F.R. 200.331. See also Section 3.14 (Subrecipient Monitoring) of the Department of Justice Financial Guide. 7. Q. The Sanctuary Policy Guidance? cited Section 13 73. Are there other components of Title 8 of the United States Code that are required for compliance? A. All grantees are required to assure and certify compliance with all applicable federal statutes, regulations, policies, guidelines, and requirements. States may wish to consult with their legal counsel if they have any questions or concerns as to the scope of this requirement. APPROVAL NO. 1121-140 EXPIRES 5/31/2019 STANDARD ASSURANCES The Applicant hereby assures and certi?es compliance with all applicable Federal statutes, regulations, policies, guidelines, and requirements, including 2 C.F.R. Part 2800 (Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards by the Department of Justice), and Ex. Order 12372 (intergovernmental review of federal programs). The applicant also speci?cally assures and certi?es that: 1. It has the legal authority to apply for federal assistance and the institutional, managerial, and ?nancial capability (including funds suf?cient to pay any required non?federal share of project cost) to ensure proper planning, management, and completion of the project described in this application. 2. It will establish safeguards to prohibit employees from using their positions for a purpose that constitutes or presents the appearance of personal or organizational con?ict of interest, or personal gain. 3. It will give the awarding agency or the Government Accountability Of?ce, through any authorized representative, access to and the right to examine all paper or electronic records related to the ?nancial assistance. 4. It will comply with all lawful requirements imposed by the awarding agency, Speci?cally including any applicable regulations, such as 28 C.F.R. pts. 18, 22, 23, 30, 35, 38, 42, 61, and 63, and the award term in 2 C.F.R. 5. It will assist the awarding agency (if necessary) in assuring compliance with section 106 of the National Historic Preservation Act of 1966 (16 U.S.C. 470), Ex. Order 1 1593 (identi?cation and protection of historic properties), the Archeological and Historical Preservation Act of 1974 (16 U.S.C. 469a?1 et seq), and the National Environmental Policy Act of 1969 (42 U.S.C. 4321). 6. It will comply (and will require any subrecipients or contractors to comply) with any applicable nondiscrimination provisions, which may include the Omnibus Crime Control and Safe Streets Act of 1968 (42 U.S.C. 3789d); the Victims of Crime Act (42 U.S.C. ?10604(e)); the Juvenile Justice and Delinquency Prevention Act of 2002 (42 U.S.C. 5672(b)); the Violence Against Women Act (42 U.S.C. 13925(b)(13)); the Civil Rights Act of 1964 (42 U.S.C. 2000d); the Indian Civil Rights Act (25 U.S.C. 1301-1303); the Rehabilitation Act of 1973 (29 U.S.C. 794); the Americans with Disabilities Act of 1990(42 U.S.C. 12131- 34); the Education Amendments of 1972 (20 U.S.C. 1681, 1683, 1685-86); and the Age Discrimination Act of 1975 (42 U.S.C. 6101?07). It will also comply with Ex. Order 13279, Equal Protection of the Laws for Faith- Based and Community Organizations; Executive Order 13559, Fundamental Principles and Policymaking Criteria for Partnerships With Faith?Based and Other Neighborhood Organizations; and the DOJ implementing regulations at 28 C.F.R. Part 38. 7. If a governmental entity~ a) it will comply with the requirements of the Uniform Relocation Assistance and Real Property Acquisitions Act of 1970 (42 4601 et seq), which govern the treatment of persons displaced as a result of federal and federally-assisted programs; and b) it will comply with requirements of 5 1501-08 and ??7324-28, which limit certain political activities of State or local government employees whose principal employment is in connection with an activity ?nanced in whole or in part by federal assistance. Signature Date