1.5.1-JOFOC_Redacted.pdf

OFFICE OF ACQUISITION MANAGEMENT

ICE Acquisition Manual 3006.301-90

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

41 USC 3304 (A): USE OF NONCOMPETITIVE PROCEDURES

Page - 2 - of 9

(f) Year of funding: FY 2026

(g) Solicitation Number: 192126VHQ4CCC0020

(h) Background information about the requirement:

CSAM represents one of the most pervasive and challenging threats in the fight against child exploitation. This crime involves offenders directing or facilitating the abuse of children in real time, often for financial profit, with buyers located across the globe. C3 CEIU has been at the forefront of combating this heinous crime, leveraging advanced investigative techniques and collaborating with international partners to identify victims, dismantle trafficking networks, and prosecute offenders. HSI has conducted undercover operations targeting sellers and buyers of live-streamed CSAM, correlating data with records to generate actionable leads. These efforts have led to significant arrests, victim rescues, and the disruption of transnational criminal organizations.

However, the evolving nature of livestreaming technology and the anonymity provided by encrypted platforms continue to pose substantial challenges to law enforcement.

Livestreaming sexual abuse of children, often referred to as Online Sexual Abuse of Children (OSEC) or Live Distance Child Abuse (LDCA), is a rapidly growing worldwide crime type that is enabling child sex offenders to gain direct access to and cause the horrific abuse of children in real time. This child abuse industry involves offenders who collect viewership fees from vetted offenders internationally, paying direct child offenders to perform acts of sexual abuse on minor children, in real time, during private webcam interactions. Offenders also often travel domestically and internationally to engage in hands-on abuse of victimized children. Due to the live private sessions and end to end encryption of the applications used by offenders, it is often difficult for law enforcement to investigate this crime type. Investigative techniques to locate and identify offenders involve the collection of large amounts of data that make it difficult to parse, cross reference and identify offenders.

3. Description of Supplies/Services.

This requirement is to procure a platform to combat the livestreaming of CSAM by tracking and identifying perpetrators. The platform is needed to overcome the evolving nature of livestreaming technology and the anonymity provided by encrypted platforms, which will assist with significant arrests, victim rescues, and the disruption of transnational criminal organizations.

4. Identification of statutory authority permitting other than full and open competition.

The statutory authority permitting other than full and open competition is 41 U.S.C. §3304 as implemented by:

RFO 6.103-1: Only one responsible source and no other supplies or services will satisfy agency requirements.

Page - 7 - of 9

8. Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

Prior to award, the Contracting Officer will determine that the anticipated price(s) will be fair and reasonable by utilizing the price analysis methodologies described in RFO Subpart 15.404-1 (Class Deviation 26-08, Rev. 1).

9. Description of Market Research.

Market Research, as required by RFO Part 10 (Class Deviation 25-06, Rev. 1), was conducted from December 2025 through March 2026, including product development and testing with CRC’s Platform and .

The Contracting Officer researched SAM.gov, the Federal Procurement Data System (FPDS), and USASpending.gov for the same or similar platforms that may have been previously procured by the Federal Government. These surveys showed that because the Platform was developed for HSI C3 it has never been previously procured by the Federal Government.

However other platforms, systems, and licenses, such as the Nemesis System and Hermes Software, have been procured for similar needs.

CSAM is contraband and must be tightly controlled. The media must be stored on premises in a controlled/encrypted environment and not accessible to a third party. CRC has an established Application Programming Interface (API) with the National Center for Missing Exploited Children, the central repository for all CSAM media, and their software can identify media files by the hash value alone. The hash value, if identified, can be compared against C3’s holdings and available to agents and analysts accessing the Platform.

was reviewed and HSI C3 provided their data to for testing. HSI C3 worked with extensively to test and assess the products’ viability. It was found that the interface was programmed in a manner requiring continued and excessive contract and account management and funding.

Similarly, did not provide a product that matched CRC’s Platform enhancements focused on integrating existing datasets, such as HSI’s CSAM database, and providing user-friendly interfaces for investigators to access bulk data and generate reports.

HSI agents could not utilize these programs without continued support from which created significant delays;, sometimes weeks, depending on availability and response times for staff. When investigating real-time online child exploitation, agents in the field must expeditiously access data independently, and extract reports for prosecution without needing to contact and work with a third-party programmer.

This determination was based on testing and review. The other products that were complimentary to the Platform, such as and , were made so robust that the platform could not be used in real-time by an average investigator or

Page - 8 - of 9 analyst to extract a user-friendly investigative interface; requiring direct support from programmers to perform the extraction, which would not only cause delays in investigations, but also require additional contractual and fiscal obligations for general use.

10. Any other facts supporting the use of other than full and open competition.

Not Applicable.

11. A listing of the sources, if any that expressed, in writing, an interest in the acquisition.

12. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for supplies or services required.

HSI C3 will continue to conduct market research and survey the marketplace to determine if there are other platforms and sources that can meet their CSAM investigations needs on subsequent requirements.