Attachment_1_Draft_Performance_Work_Statement_1.pdf

Sources Sought Notice: Performance Work Statement (PWS) for Investigative and Litigation Support Services

Health and Human Services (HHS), Office of the Inspector General (OIG), Office of Investigations (OI)

1. Introduction

The purpose of this task order is to provide investigative and litigation support services for criminal investigation cases and activities. The contractor will be tasked with a thorough review and analysis of raw financial data, specifically bank and cryptocurrency records, to assist in the investigation of fraudulent activities and money laundering.

2. Objective

The objective of this task order is to conduct a comprehensive analysis of financial and relevant data.

This analysis will enhance the capabilities of federal investigators and prosecutors in their ongoing efforts to recover the misappropriated funds and ensure accountability.

The contractor will be responsible for the following tasks:

3.1 General Analysis

The contractor will conduct a comprehensive general financial analysis involving the following detailed steps:

• Identification of Significant Transactions:

o Perform a transaction-by-transaction review of financial records (bank and cryptocurrency exchange records) to identify large sums, out-of-pattern transactions, or high-frequency transactions that stand out against historical norms for each account.

o Flag any transactions that could be considered potential money laundering transactions (transactions intended to disguise the proceeds, sources, or nature of illicit activities) and/or structured transactions (transactions designed to avoid BSA reporting requirements).

• Trend Analysis:

o Analyze temporal factors by creating time-series models that identify patterns or trends in transactions over days, weeks, or months.

o Investigate spikes or anomalies in transaction volumes or amounts that could suggest illicit activity or sudden changes in financial behaviors, providing a timeline of suspicious activities that may correlate with external events or investigations.

• Preparation of Preliminary Findings:

o Summarize key insights and findings in an interim report format to share with key stakeholders, including investigators and legal teams, for immediate actionable steps.

o Include suggested areas for deeper analysis and potential follow-up actions based on evidence collected.

3.2 Data Review and Analysis

The contractor will perform an extensive review and analysis of financial data through the following steps:

• Focused Data Review:

o Gather and review raw financial data, bank records, and cryptocurrency records necessary for the investigation. Limit analysis to the most relevant data, ensuring quality over quantity.

• Reconciliation of Accounts:

o Reconcile bank account records to confirm the accuracy of transaction entries and identify any missing or anomalous data.

• Fraud Detection Techniques:

o Utilize basic techniques to identify potentially fraudulent transactions, highlighting connections based on obvious patterns.

o Perform an advanced link analysis, detecting connections between entities, funds, and transactions to illustrate networks of potential fraudulent activity.

o For cryptocurrency transactions, utilize forensic analysis and blockchain intelligence tools to develop attribution data on account owners and identify clusters of interrelated addresses under common control.

• Graphical Data Representation:

o Create detailed charts, graphs, and flow diagrams that depict the movement of stolen or suspicious funds as requested by investigative team.

o Develop clear visual presentations that showcase how funds were transferred between accounts, highlighting key nodes that require further investigation.

o Schedule out select bank accounts, creating a chart displaying the aggregated sources of funds for each account (by payor) and a chart displaying the aggregated use of funds for each account (by payee)

• Reporting and Documentation:

o Prepare detailed financial reports that include findings from the data analysis, visual representations, and patterns identified throughout the review.

4. Deliverables

The contractor shall provide the following deliverables:

• Detailed Analysis Report: A comprehensive report summarizing the thorough analysis of all financial data, highlighting key findings, patterns, and evidence of fraudulent activities or money laundering.

• Monthly progress reports detailing analysis findings and ongoing activities related to financial review.

• Graphical representations of the flow of funds, including charts and diagrams indicating transactional pathways of misappropriated funds and charts summarizing the aggregated inflows and outflows for select bank accounts.

• Comprehensive financial reports tailored for identified and selected stakeholders (e.g., agents) review upon request.

• An end-of-task report summarizing the analysis performed, key findings, and any recommendations for further investigation.

5. Period of Performance The Period of Performance (POP) for this task order is anticipated to be 12-months, starting from the date of contract award. The POP may be extended subject to the needs of the investigation and the availability of funding. Additional support may be required beyond the initial period based on ongoing investigative requirements and needs.

6. Qualifications

Proposals will be evaluated based on the contractor's demonstrated expertise in the following areas:

• Specialized Expertise in Litigation Support: The contractor shall possess specialized expertise in litigation support, with a team that includes certified fraud examiners and accredited healthcare fraud investigators. This expertise is essential for accurately assessing and interpreting complex financial data within a legal context.

• Proprietary Technology Utilization: The contractor shall have an in-house, proprietary database designed for extensive bank record analysis, forensic accounting, cryptocurrency forensics and asset tracing, and litigation services. This database should enable the upload of comprehensive bank account data, including statements, account holder information, deposits, checks, wire transfers, and other financial transactions.

• Analytical Capability: The proprietary database should generate detailed electronic reports for link analysis of accounts, subjects, and transactions. This capability will facilitate the identification of linked accounts and investigative subjects for further examination, supporting both criminal and civil litigation.

• Experience in Financial Investigations: A proven track record in financial investigations, forensic accounting, cryptocurrency forensics and asset tracing, and litigation support is essential. This experience should include familiarity with federal investigations and collaboration with law enforcement agencies.

• Communication and Reporting Skills: The contractor must demonstrate the ability to produce clear, concise reports and visual displays of financial data tailored to diverse audiences, including federal agents, attorneys, and stakeholders. Effective communication is critical for conveying complex financial information and findings.

• Qualified Personnel: The contractor should employ qualified personnel, including individuals with relevant certifications (e.g., CPA, CFE) and a strong background in investigative support services. Experience in similar investigations involving large-scale financial fraud, cryptocurrency, or misuse of funds is preferred.