Sanctions Financial Threat Support

The Department of the Treasury Departmental Offices established a Master IDIQ for Sanctions Support and Threat Financial Analysis on September 28, 2011, with a last date to order of March 27, 2017—this vehicle is now closed and no longer accepting new orders.

The vehicle is inactive. Ordering closed nine years ago, and the most recent task order was awarded on April 17, 2017. The 53 task orders issued under the vehicle generated a combined potential value of $98.9 million, of which $93.8 million (95 percent) has been obligated. Peak ordering activity occurred in 2014–2017, when the vehicle sustained a steady pace of seven task orders per year.

The work spans sanctions compliance and enforcement, financial investigations, policy analysis, and FOIA request processing. Task orders address licensing support, investigations into terrorism financing and professional money laundering networks, special measures compliance programs, and analytical support to Treasury's Office of International Affairs. Representative orders include a $31.1 million Professional Money Laundering (3PML) investigations support contract to Deloitte Financial Advisory Services LLP, a $11.5 million Sanctions TNT Investigation contract to Booz Allen Hamilton Inc., and a $7.2 million General Compliance Network (GCN) investigation contract to Strategic Intelligence Group, L.L.C.

Three firms dominated the vehicle: Deloitte Financial Advisory Services LLP captured $46.1 million (47 percent of combined potential value) across 8 orders; Booz Allen Hamilton Inc. held $25.9 million across 10 orders; and Strategic Intelligence Group, L.L.C. accounted for $15.3 million across 11 orders. These three firms represent 97 percent of the vehicle's combined potential value. FCI Federal, LLC and BAE Systems Information Solutions Inc. each held smaller positions at $4.3 million.

Customer concentration was high: the Department of the Treasury Departmental Offices placed 47 orders valued at $88.6 million (89 percent of combined potential value), while the Treasury Financial Crimes Enforcement Network placed 6 orders worth $10.2 million. All 53 task orders were unrestricted, with no set-asides applied. Task order ceiling values ranged widely, from under $150,000 to $31.1 million, with firm fixed price being the predominant pricing mechanism and labor-hours used selectively for FOIA and enforcement support work.

Sanctions Support and Threat Financial Analysis