47QFDA22K0012_Justification Other Than Full Open_2022-06-06.pdf

General Services Administration (GSA)

National Capital Region (NCR) Federal Acquisition Services (FAS)

JUSTIFICATION AND APPROVAL

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

FOR THE SPECIAL INVESTIGATOR GENERAL FOR AFGHANISTAN

RECONSTRUCTION (SIGAR) REPORT GENERATION

TASK ORDER 47QFDA22K0012

INTERAGENCY AGREEMENT NUMBER 47QFDA22S0005

The General Services Administration (GSA) makes this Justification and Approval

(J&A) for Other Than Full and Open Competition orders pursuant to Federal

Acquisition Regulation (FAR) 6.302.

1) Identification of Agency and Contracting Activity:

Agency:

General Services Administration (GSA)

National Capital Region (NCR) Federal Acquisition Services (FAS)

Acting in support of: Special Investigator General for Afghanistan Reconstruction

(SIGAR)

Contracting Activity:

GSA NCR/FAS/AAS

1800 F Street, NW

Washington, D.C. 20405

2) Nature and/or Description of Action Being Approved:

The Office of the Special Inspector General for Afghanistan Reconstruction (SIGAR) needs people to research open-source records held domestically and internationally. This need must be issued as a sole source, four (4) month contract to meet the mission requirement.

Estimated Period of Performance: The estimated period of performance is from May

31, 2022, through September 30, 2022.

Procurement Estimated Value:

Base Period: $250,000.00

GSA Fee 20%: $50,000.00

Total: $300,000.00

(Estimate subject to change).

Contract Type: Firm Fixed Price

DocuSign Envelope ID: 5AE86F27-911A-4BBA-9816-6F02B1AB3572

Current Contract Information: This is a new requirement – no previous or current contract.

Period of Performance for the Contract is outlined below:

Base Period: May 31, 2022 – September 30, 2022

3) A Description of Supplies/Services Required to Meet Agency’s Need:

SIGAR requires assistance in open-source research of records contained in both domestic and international jurisdictions. The contractor shall provide required research using its access to ground networks in various jurisdictions such as the USA, UK, Turkey, UAE, Afghanistan and adjacent countries to gather, synthesize and produce target record search results. SIGAR will use this information to document and support recovery of monies taken illegally. Performing these functions are necessary to complete SIGAR’s congressionally mandated mission.

4) An Identification of the Statutory Authority Permitting Other Than Full and Open

Competition:

The authority under which this JOFOC is made is pursuant to FAR 6.302:

a. FAR 6.302-3(a)(2)(ii), To establish or maintain an essential engineering, research, or development capability to be provided by an educational or other nonprofit institution or a federally funded research and development center.

This Sole Source Contract will be awarded pursuant to the authority of 41 United States

Code (U.S.C.) 3304 as implemented by FAR 6.302-3(a)(2)(ii) supra.

5) A Demonstration that the Proposed Contractor’s Unique Qualifications or the

Nature of the Acquisition Requires Use of the Authority Cited:

For the following reasons, it is determined only one source, C4ADS, can meet the operational requirements of SIGAR with the highest degree of confidence and minimal potential delays. SIGAR requires immediate utilization of personnel and intelligence networks in the US, UK, Switzerland, Turkey, United Arab Emirates, Afghanistan and possibly other countries adjacent thereto to prepare these reports. C4ADS is the only vendor currently known to have the personnel and expertise immediately available to conduct this requirement. It also has the proven skills necessary to perform the required services; its public website contains an example of the specific type of report SIGAR is seeking. C4ADS has historical knowledge, data and readily available intelligence on transnational corrupt illicit networks and money laundering proceeds to assist SIGAR in the immediate identification of actors and entities involved and the construction of charts and link analysis products outlining the jurisdictions and connections involved. These charts and C4ADS’s repository of intelligence data can be directly used to support

SIGAR's investigations of individuals engaged in illegal activities involving US

Reconstruction monies and fall of the Afghan government.

6) A Description of Efforts Made to Ensure that Offers are Solicited From as Many

Potential Sources as Practicable:

As required by FAR Part 5.201, on March 29, 2022, the Contracting Officer published a

SAM Sources Sought synopsis stating the Government’s plan to Sole Source this acquisition. Other market research tools used for identifying other potential sources included contacting knowledgeable individuals in Government & Private Industry;

Publishing a Formal RFI (RFQ1545150 OASIS Pool1; no responses received); and reviewing various available GSA contract vehicles (GWAC’s, OASIS, MAS) and other potential-source databases (SBA DSBS; ICD; non-GSA GWAC’s; MAC’s; GSA

Advantage!).

7) A Determination by the Contracting Officer that the Anticipated Cost to the

Government will be Fair and Reasonable:

[Based on the data gathered, the Contracting Officer has determined that the anticipated cost to the Government will be fair and reasonable. The expectation of reaching a fair and reasonable price was determined through market research in order to determine best value for SIGAR.] The total amount of funding required for the total estimated period of four

(4) months is approximately $250,000.00.

8) A Description of the Market Research Conducted and the Results or a Statement of the Reason Market Research was not Conducted:

GSA/FAS/AAS conducted market research. Below are the findings:

Techniques Utilized:

Contacted knowledgeable individuals in Government & Private Industry; Published

Formal RFI (RFQ1545150 OASIS Pool 1; 9 responses received).

Techniques & Methods Utilized:

AbilityOne procurement list reviewed per FAR 8.7. No overseas investigatory vendors found.

GSA GWACS (Alliant, VETS, 8(a)STARS2: No overseas investigatory vendors found.

GSA IDIQ's (OASIS): No overseas investigatory vendors found.

GSA Schedules: One potential vendor found on GSA Schedule. (Kroll Inc. e-mail response dated 3/22/22).

Non-GSA GWACs, MACs: No overseas investigatory vendors found.

ICD: No overseas investigatory vendors found.

SBA DSBS: No overseas investigatory vendors found.

GSA/FSS (GSA Advantage): Kroll Inc. (covered above) & Guidehouse Inc. were found. RFI's e-mailed to each firm 3/18/22, due 3/25/22. Kroll Inc. responded;

Guidehouse gave no response.

Summary of Research:

A. The Government's needs can be met by C4ADS.

B. Commerciality: Commercial with modifications (Middle East locations; Anti-

Terrorist Training; Public Trust).

C. Set-Aside: No two SB sources could be found.

Socio-Economic status N/A.

Mentor-Protege N/A

TA's & JV's: N/A

Conclusion:

Pursue sole source with C4ADS.

9) Any Other Facts Supporting the Use of Other Than Full and Open Competition:

This action is not a request for competitive proposals and/or a solicitation for offers.

10) A Listing of the Sources, if any, That Expressed, In Writing, An Interest in the

Acquisition:

C4ADS (e-mail dated 3/29/22)

SIGAR SME reviewed C4ADS’ public website and confirmed it produces reports of the exact type meeting these requirements.

Kroll Inc. (e-mail dated 3/22/22)

SIGAR SME reports Kroll Inc. does not do the specific type of investigation(s) required here. The one report available for review was done for other purposes and did not result in any charges or convictions of individuals suspected of engaging in illicit or illegal activity.

Advanced Decision Vectors LLC (RFI response 3/18/22)

SIGAR SME reviewed the information submitted along with the company’s public website, and reports the Government would have to work closely with and advise the company on doing this work. This is impractical given the international nature of the work and the time in which it is required.

DarkStar Intelligence (RFI response 3/18/22)

Financial crimes investigatory experience lacking. The Government may have to teach what it specifically needed. This is impractical given the international nature of the work and the time in which it is required.

Halifax Group LLC (RFI response 3/18/22)

No additional information provided with response. SIGAR SME unable to evaluate specific capabilities.

McColm and Company (RFI response 3/18/22)

NKCC LLC (RFI response 3/18/22)

Prescient Technologies (RFI response 3/18/22) specific capabilities. Question from company indicated it may need lead time, which is unavailable to SIGAR.

Redlock Solution LLC (RFI response 3/18/22)

SIGAR SME reviewed the information submitted and reports most experience found does not involve intelligence work. No public website could be found.

RESCUE ME LLC (RFI response 3/18/22)

Valens Global (RFI response 3/18/22)

11) A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome

Any Barriers to Competition Before Any Subsequent Acquisition for the Supplies or

Services Required:

None, due to the specific, sensitive nature of the investigations.

12) Contracting Officer Certification that the Justification is Accurate and Complete to the Best of the Contracting Officer’s Knowledge and Belief:

I certify that this justification is accurate and complete to the best of my knowledge and belief, and I determine on the basis of the findings above that an approach of other than full and open competition is in accordance with the requirements and is in the best interest of the Government.

Victor Purcell Date

Contracting Officer

NCR/FAS/COD

6/6/2022