JOFOC.pdf
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This is a Justification for Other Than Full and Open Competition (JOFOC) form for a sole source contract renewal.
The Internal Revenue Service—Criminal Investigation Division seeks to renew contract 2023H2-25-C-00135 with TRM Labs, Inc. through a Firm Fixed Price (FFP) arrangement for blockchain analytics and investigative support services. The contract supports IRS-CI's digital asset investigation mission in collaboration with federal, state, local, and international law enforcement partners. The base period runs from September 29, 2026 to September 28, 2027, with four optional one-year renewals extending through September 28, 2031. The total estimated contract value is $30,522,650.00, with each annual period valued at $6,104,530.00. The procurement authority is cited under 41 U.S.C. § 3304(a)(1), permitting sole source acquisition based on brand name specification.
The justification establishes that TRM Labs is the only responsible commercial provider capable of meeting the Government's minimum operational requirements for blockchain analytics, investigative support, training, and certification services without unacceptable technical or operational risk. Market research, including publication of a Request for Information (RFI) on SAM.gov, confirmed no alternative sources could satisfy requirements. Continued reliance on TRM is necessary to maintain operational continuity with partner agencies, preserve existing investigative workflows and data maintained in TRM's proprietary format, and avoid costly retraining and data reconstruction. The Contracting Officer will perform price analysis prior to award using historical pricing comparisons, current commercial practices, the Independent Government Cost Estimate, market research, and escalation trends to determine fair and reasonableness. The acquisition does not result from poor planning or fund expiration.
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Text version
IRS Form (Rev. 5/26)
RFO 6.103
B. DESCRIBE THE EFFORTS TAKEN TO ENSURE OFFERS WERE SOLICITED FROM AS MANY
POTENTIAL SOURCES AS IS PRACTICABLE, INCLUDING WHETHER A NOTICE WAS OR
WILL BE PUBLISHED AS REQUIRED BY RFO PART 5 AND, IF NOT, WHICH EXCEPTION
UNDER RFO PART 5 APPLIES.
A Request for Information based on this requirement was published on SAM.gov to all vendors.
C. DETERMINATION THAT THE ANTICIPATED COST TO THE GOVERNMENT WILL BE FAIR
AND REASONABLE.
Prior to contract award, the Contracting Officer will determine that the proposed price is fair and
RFO 6.103
reasonable through the application of appropriate price analysis techniques consistent with the commercial nature of this acquisition. Although price competition is not available, the Contracting Officer will perform an independent assessment using a combination of relevant pricing information, as appropriate, including comparison with historical prices paid for the same or similar commercial products and services, evaluation of current commercial pricing and licensing practices, review of the Independent Government Cost Estimate (IGCE), analysis of proposed pricing trends and escalation, comparison with available market research, and any other relevant commercial pricing information available to the Government. The Contracting Officer will consider the totality of the pricing information obtained to determine whether the proposed price reflects a fair and reasonable commercial price for the supplies and services being acquired. The detailed price analysis supporting this determination will be documented in the contract file prior to award.
D. DESCRIBE THE MARKET RESEARCH THAT WAS CONDUCTED AND THE RESULTS OR A
STATEMENT OF THE REASON MARKET RESEARCH WAS NOT CONDUCTED. IF ACTIONS
WERE TAKEN BY PROCUREMENT PERSONNEL TO SATISFY THIS REQUIREMENT (SUCH
AS A SOURCES SOUGHT NOTICE), PLEASE SPECIFY.
Comprehensive market research was conducted in accordance with applicable acquisition procedures to identify commercially available sources capable of satisfying the Government's minimum requirements for blockchain analytics, investigative support, training, and related law enforcement capabilities. The market research included publication of a Request for Information (RFI) for Blockchain Analytics and Intelligence Provider (BAIP) resources, review of commercial capabilities, evaluation of vendor responses, and assessment of available products against the Government's identified operational requirements.
TRM Labs is the only responsible source capable of meeting the Government's minimum operational requirements without unacceptable technical, operational, or schedule risk.
E. DESCRIBE ANY OTHER FACTS SUPPORTING USING OTHER THAN FULL AND OPEN
COMPETITION.
IRS-CI currently relies on TRM Labs to support active digital asset investigations and collaboration with Federal, state, local, and international law enforcement partners. Continued access to the TRM platform is necessary to maintain operational continuity, preserve interoperability with partner agencies, and support ongoing investigations.
Transitioning to an alternative commercial solution would require investigators to recreate investigative workflows, retrain personnel, and manually reconstruct investigative data currently maintained in TRM's proprietary graph format. This would delay ongoing investigations, reduce operational efficiency, and increase the risk of incomplete or inconsistent investigative analysis.
F. LIST SOURCES, IF ANY, THAT EXPRESSED, IN WRITING, AN INTEREST IN THE
ACQUISITION.
RFO 6.103
G. LIST THE ACTIONS THE BUREAU WILL TAKE TO REMOVE OR OVERCOME ANY BARRIERS
TO COMPETITION ON ANY SUBSEQUENT ACQUISITIONS FOR THE SUPPLIES OR
SERVICES REQUIRED.
The Contracting Activity will continue to search the marketplace for potential sources by holding industry days; publishing acquisition forecasts, etc. For future requirements, the Requiring Activity will continue to conduct market research of the current environment, as well as investigate marketplace products and services, to ensure that competition remains available. Every opportunity will be taken to ensure that fair opportunity is achieved.
H. STATEMENT THAT REQUIREMENT DOES NOT RESULT FROM A LACK OF PLANNING OR
THE EXPIRATION OF FUNDS.
Requirement does not result from lack of planning or the expiration of funds.
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