Justification for Other Than Full and Open Competition (J&A)

This document is a Justification for Other Than Full and Open Competition (J&A-26-0163) submitted by the U.S. Department of Homeland Security, Immigration and Customs Enforcement (ICE) for a sole-source contract award to TRM Labs, Inc. (450 Townsend Street, San Francisco, CA 94107). The procurement supports the Homeland Security Task Force National Coordination Center Cyber Disruption Center (CDC) and is based on the authority of 41 U.S.C. §3304(a) under RFO 6.103-1, which permits noncompetitive procedures when only one responsible source exists.

The contract is for advanced analytical and artificial intelligence platform support services, including skilled intelligence analysts and technology solutions for real-time monitoring, tracing, and disruption of illicit financial flows. The procurement is structured as a Firm Fixed Price contract with solicitation number 192126VHQ4CCC00XX and encompasses multiple mission priorities over the period July 1, 2026 through June 30, 2027. The contract includes three base CLINs (Mission Priority 1, 2, and 3) and four optional surge/travel CLINs, with funding provided through One Big Beautiful Bill (OB3) multi-year appropriations. The justification documents extensive market research conducted via an RFI posted on SAM.gov (May 28 – June 2, 2026) with eight vendor responses and a subsequent Notice of Intent to Sole Source (closed June 11, 2026). The agency determined that TRM Labs is the only source capable of delivering the integrated capabilities required to support the CDC's mission to combat cyber-enabled fraud, ransomware, and sextortion targeting critical infrastructure, financial institutions, and vulnerable populations under Executive Order 14390.