Illegal Transshipment Pilot CSOP Solicitation Questions and Answers April 15 2026.xlsx
XLSX spreadsheet 52 KB Posted
- Solicitation number
- CSOP-BP-GS-26-0001
About this file
This is a Questions and Answers (Q&A) document addressing 257 inquiries from prospective offerors regarding the DHS/CBP Illegal Transshipment Pilot Commercial Solutions Opening (CSOP-BP-GS-26-0001). The document provides government responses clarifying solicitation requirements, evaluation criteria, data delivery mechanisms, performance metrics, and contract terms for vendors submitting AI-driven solutions to detect illegal transshipment in maritime cargo.
The pilot operates as a two-phase procurement with a no-cost, 180-day base period followed by two optional one-year periods capped at $1,250,000 each. CBP will provide approximately 1,500 manifest records daily (Monday-Thursday) via password-protected Excel files containing nine data fields for imports from approximately five designated high-risk countries, with no historical data provided for model training. Vendors must independently develop referral packages identifying in-transit illegal transshipment risk, supported by minimum five pages of substantive evidence, submitted via email with proposed formats (PDF preferred). Performance is measured across three 60-day gates with escalating accuracy thresholds (10%, 30%, 50% for base period; 70%, 90% for options) calculated only against referrals CBP investigates, and scalability thresholds (minimum two referrals per week at Gate 1, escalating to two per day at Gate 3). CBP may select multiple vendors for parallel participation, each operating independently with identical manifest data; vendors may augment CBP data with commercially available sources and may engage supply chain participants for voluntary data collection, but the pilot excludes mechanisms for reducing enforcement scrutiny based on voluntary transparency. Solutions must operate in vendor-hosted environments with no CBP system connections, background investigations are not required, and IP rights to referral packages and vendor-derived insights are negotiated pre-award consistent with FAR 52.227-14, while vendors retain ownership of proprietary models and commercial data. Regular weekly or biweekly feedback meetings will address actionability and enforcement outcomes to support model refinement; CBP retains discretion to issue stop-work orders mid-gate if performance thresholds are not met.
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Sheet1
| CSOP-BP-GS-26-0001 Q&A with Government Responses | ||||
| No. | Solicitation Document | Document Section | Question | Government Response |
| 1 | Solicitation | 1.1 Background / General | Given that this is a full and open opportunity, does CBP view this pilot as primarily oriented toward large business participation, or does CBP also anticipate meaningful participation by small businesses, including as prime offerors or through teaming arrangements? | CBP welcomes and encourages participation from both large and small businesses, including as prime offerors or through teaming arrangements. The CSOP process is specifically designed to attract a broad range of innovative commercial solutions from both traditional and non-traditional government contractors. |
| 2 | Solicitation | 4.1 General / 4.2 Evaluation Timeline and Phases | Does CBP anticipate making awards to multiple vendors for parallel pilot participation during the base period, or is a single award currently contemplated? | CBP may make multiple awards for parallel pilot participation during the base period. The solicitation states that it is within the Government’s discretion to accept more than one solution brief for award resulting from this solicitation. |
| 3 | Solicitation | 3.2.1 Content of Solution Brief | If a prime offeror proposes a team that includes subcontractors or teaming partners, may the team submit one integrated solution brief, and if selected, may authorized data access and performance responsibilities be shared across that team, subject to applicable security and data handling requirements? | Yes, a team may submit one integrated solution brief. If selected, authorized data access and performance responsibilities may be shared among team members, provided all parties comply with applicable security and data handling requirements as outlined in the solicitation and SOW. |
| 4 | SOW | 2.0 Scope / 6.0 Deliverables and Support | The SOW states that only referral packages CBP chooses to investigate and act upon will be factored into the assessment of accuracy. Can CBP clarify how referral packages that are submitted but not selected for action will be treated for evaluation purposes, and whether vendors will receive feedback on those submissions? | Feedback will be provided during routine meetings to be held on a weekly or biweekly cadence. CBP will provide feedback on whether referral packages are actionable. |
| 5 | SOW / Solicitation | 2.0 Scope / 2.0 Project Description | If a vendor successfully meets the base period and option period performance thresholds, does CBP currently anticipate a follow-on production acquisition or other scaling path after completion of the pilot? | The results of this technology demonstration may inform an enterprise-wide, competitive procurement for AI-driven illegal transshipment detection tools. Any follow-on acquisition or scaling will be determined based on the outcomes of the pilot and CBP’s operational needs. The procurement strategy for a follow on acquisition after this pilot cannot be determined at this time. The results of the pilot do not guarantee any future work for participating vendors. |
| 6 | SOW | 2.0 Scope | In what file format will the manifest data be provided (e.g., CSV, JSON, XML, fixed-width flat file)? Will the data schema and field definitions be documented in a data dictionary provided at contract kickoff? | Password protected excel file. |
| 7 | SOW | 2.0 Scope | What secure transfer mechanism will be used to deliver manifest data to vendors (e.g., SFTP, AWS S3 bucket, secure API endpoint, encrypted email)? Will vendors be required to establish connectivity to a CBP-designated system, or will CBP push data to a vendor-designated endpoint? | Establishing a connection to a CBP-designated system will not be required. |
| 8 | SOW | 2.0 Scope | What is the approximate number of manifest records CBP anticipates providing to each vendor per day or per batch? | Approximately 1500 records will be supplied daily M- TH via an e-mailed Password protected excel file. |
| 9 | SOW | 2.0 Scope | Will manifest data be provided as a single daily batch, multiple batches per day, or on a rolling/continuous basis as shipments are identified? | Manifest data will be provided as a single daily batch |
| 10 | SOW | 2.0 Scope | Will the list of high-risk countries be communicated to vendors at contract kickoff? Should vendors expect this list to evolve during the base period? | A list of high-risk countries will be provided to vendors at contract award. They will remain the same for the duration of the base period |
| 11 | SOW | 6.0 Deliverables and Support | Is there a preferred or required format for the referral package document (e.g., PDF, Word, standardized template)? Does CBP anticipate providing a referral package template, or should vendors propose their own format? | Vendors should propose their own format as part of the application process. PDF is preferred. Word is acceptable. |
| 12 | SOW | 6.0 Deliverables and Support | Can CBP clarify the anticipated cadence of feedback on referral packages (e.g., weekly, biweekly, monthly), and whether the feedback will be provided in a structured format or as a narrative assessment? | Feedback will be provided during routine meetings to be held on a weekly or biweekly cadence. |
| 13 | SOW | 6.0 Deliverables and Support | Can CBP clarify: (a) the denominator for accuracy calculation — is accuracy calculated as a percentage of all referrals submitted, or only those CBP chooses to investigate?; and (b) the timeline for determining accuracy — at what point after submission is a referral considered "accurate" or "not accurate"? | Accuracy is measured as the percentage of CBP-actioned referrals that result in successful enforcement outcomes. The denominator is the number of referrals CBP chooses to investigate. False positives and non-selected referrals are not included in the accuracy calculation |
| 14 | SOW | 6.0 Deliverables and Support | Is there a maximum number of referral packages vendors should submit per day or per week? Does submitting referrals above the minimum threshold affect evaluation positively? | Submitting referrals above the minimum threshold does not affect evaluation. Accuracy is measured as the percentage of CBP-actioned referrals that result in successful enforcement outcomes. |
| 15 | SOW | 7.1 IT Security Compliance | Can CBP confirm that vendors are expected to provision and maintain their own computing environment (e.g., commercial cloud such as AWS GovCloud) for data processing and analysis, rather than operating within a CBP-provided environment? | Yes. Vendors will operate in their own computing environment. |
| 16 | SOW | 7.1.3 Security Authorization | Given the 180-day base period, can CBP provide guidance on the expected timeline for completing the Security Authorization process? Will vendors be expected to begin processing manifest data before the Security Authorization is fully completed, or must authorization be in place before data transfer begins? | During the initial 180 day contract, no connection to CBP Systems is required. Referral Packages will be transmitted to CBP via e-mail. Security Authorization is not required. |
| 17 | SOW | 7.1.2 Basic Requirements | SOW Section 7.1.2(c) states vendors "shall not remove image data from systems nor store said data on contractor networks." Can CBP clarify whether this restriction applies specifically to image data (photographs, scans) or to all CBP-provided manifest data? | Vendors to do not have access to CBP systems. Vendors only have access to the manifest data sent to them. |
| 18 | Solicitation | 2.0 Project Description / 4.2 Evaluation Timeline | Can CBP provide guidance on the anticipated number of vendors that may be selected for the base period pilot? Will all selected vendors receive the same manifest data, or will the data be segmented among vendors? | There is no predetermined maximum number of awards. CBP may select as many vendors at their discretion. The same manifest data will be provided to all the selected vendors. |
| 19 | Solicitation | 2.0 Project Description / 4.2 Evaluation Timeline | Will selected vendors operate independently and in isolation from one another, or does CBP anticipate any coordination or information-sharing among pilot participants? | Vendors will operate indepenently from each other. |
| 20 | Solicitation | 2.0 Project Description | Does CBP anticipate a formal kickoff meeting or onboarding process for selected vendors? If so, will this include detailed technical specifications for data exchange, referral package requirements, and security authorization procedures? | Yes, there will be a formal kick-off meeting after contract award with each vendor seperatley. Each vendor is required to provide a sample referral package as part of its solution brief. CBP will provide referral packages feedback to vendors who are selected to participate in the pilot. |
| 21 | SOW | 3.0 Period of Performance / 6.0 Deliverables | Is there any ramp-up or onboarding period before the 180-day performance clock begins, or does the 180-day period begin immediately upon contract award regardless of operational readiness? | The 180-day base period begins upon contract award. |
| 22 | SOW | 6.0 Deliverables and Support | Can CBP clarify: (a) whether a vendor failing to meet one gate's threshold results in immediate stop work, or whether CBP allows a cure period?; and (b) is stop work at one gate final, or can a vendor that fails Gate 1 continue if it demonstrates improvement? | (a) CBP reserves the right to issue a stop work order if thresholds are not met, but may allow a cure period at its discretion. (b) Stop work is generally final for that base period, but CBP may consider continued participation if improvement is demonstrated and resources permit. |
| 23 | SOW | 2.0 Scope / 6.0 Deliverables | Can CBP confirm that vendors are permitted to supplement CBP-provided manifest data with commercially available, publicly accessible data sources in their analysis and referral packages? | This is correct. |
| 24 | Solicitation | General / Background | We are aware of and recently responded to another CBP Trade Solutions Pilot (TSP) CSOP (CSOP-BPGS-25-0001) that is open (SAM link). Would the Government be able to explain the relationship and/or difference between the CBP TSP CSOP (CSOP-BPGS-25-0001) and this Illegal Transshipment CSOP (CSOP-BP-GS-26-0001)? | The Illegal Transshipment CSOP is specific to exploring private sector solutions to identifying illegal transshipment risk, while the Trade Solutions Pilot explores a wider scope of operational needs, including automated HTS classification and value/country of origin validations. |
| 25 | SOW | 2.0 Scope | We understand that during the period of performance (PoP) selected vendors may choose to receive manifest data from CBP as described in Section 2.0 of the SOW. Can the Government explain how and in what format vendors will receive the manifest data? | Vendors will receive the data through a password protected Excel file via e-mail. |
| 26 | SOW | 2.0 Scope / Solicitation 3.2.1 | Will the Government provide a sample of the manifest data that will be provided during the PoP to inform vendor responses to Section 3 of the CSOP submission (i.e. the Sample Illegal Transshipment Referral Packages)? | Negative. |
| 27 | SOW | 2.0 Scope / 6.0 Deliverables | Will the Government provide examples of relevant indicators of illegal transshipment to inform vendor referral packages prior to or during the PoP? | Negative. |
| 28 | SOW | 6.0 Deliverables and Support | Will the Government provide a template for exemplar referral packages prior to or during the PoP? | Negative. |
| 29 | Solicitation / SOW | General | Are there any providers already performing a similar scope of work for CBP today? If so, who are those providers? | CBP is unable to share this information. CBP does not currently have contracts that primarily support this effort. CBP is searching for innovative commercial solutions with this procurement effort. |
| 30 | Solicitation / SOW | General | DHS acquisition policies and guidance emphasize expanding participation from non-traditional and commercial vendors, including through the use of flexible acquisition pathways such as this CSOP, which are intended to reduce barriers to entry, increase competition, and accelerate the adoption of innovative technologies, including AI/ML. Given this emphasis, would the Government consider structuring this effort as a funded pilot or prototype rather than an unfunded 6-month pilot to better align with these objectives and avoid unintentionally limiting participation from non-traditional or commercial vendors? | Negative. |
| 31 | SOW | 7.0 IT Security Compliance Requirements | Please clarify the expected timeline and scope of compliance with the IT Security Compliance Requirements in SOW Section 7.0 during the no-cost base period of performance. Specifically, which requirements must be in place prior to the start of the base period of performance, and which may be achieved progressively during the base period? Are any of these requirements preconditions for contract award? | During the initial 180 day contract, no connection to CBP Systems is required. Referral Packages will be transmitted to CBP via e-mail. |
| 32 | SOW | 6.0 Deliverables and Support | SOW Section 6.0 specifies content requirements for referral packages but does not reference a required format or template. Does CBP have a preferred format for referral packages (e.g., PDF, structured data file, specific template), or may vendors define their own format provided it meets the substantive requirements? | Vendors should propose their own format. PDF is preferred. Word is acceptable. |
| 33 | SOW | 6.0 Deliverables and Support | SOW Section 6.0 states that CBP will provide "regularly scheduled feedback" on whether referral packages meet the criteria for being considered actionable and whether they lead to enforcement outcomes. What is the anticipated cadence of this feedback (e.g., per package, weekly, per performance gate)? | Feedback will be provided during routine meetings to be held on a weekly or biweekly cadence. |
| 34 | SOW | 2.0 Scope | SOW Section 2.0 states that CBP will make manifest information available to vendors no later than 72 hours before imports are expected to arrive. What is the anticipated delivery mechanism for this data (e.g., email, secure file transfer, portal access)? | CBP will make manifest information available to selected vendors via email. |
| 35 | Solicitation | 8.33 (HSAR 3052.204-71) | Section 8.33 (HSAR 3052.204-71) requires background investigations for contractor personnel. May vendor personnel begin work during the base period under interim status while investigations are pending, or must final suitability determinations be completed before the base period of performance starts? | A BI will not be required however, vendors must protect the transmission of data via password and other security measures outlined in the SOW and contract terms and conditions. Contractor personnel will not require CBP systems access or facility access. |
| 36 | SOW | 2.0 Scope | Will CBP provide manifest data to all participating vendors simultaneously, or will access be phased or selective? If selective, what criteria determine which vendors receive manifest data? | Near simultaneously via e-mail. All selected vendors will receive the manifest data, should they choose to receive it. |
| 37 | SOW | 2.0 Scope | Will vendors have access to historical manifest data prior to the base period start to train, validate, and calibrate their AI models, or only prospective 72-hour advance data during performance? | Negative. Vendors will be given access to prospective data upon award. |
| 38 | SOW | 2.0 Scope | May vendors supplement CBP-provided manifest data with commercially available trade databases, sanctions lists, corporate registry data, or open-source intelligence (OSINT)? If so, are there restrictions on which external data sources are permissible? | Yes, Vendors may supplement CBP data. Vendors should be prepared to explain their data sources. |
| 39 | SOW | 2.0 Scope | What is the expected volume of daily manifests CBP will provide? Understanding approximate scale is critical for infrastructure sizing and scalability planning. | Approximately 1500 records will be supplied daily M- TH |
| 40 | SOW | 6.0 Deliverables and Support | What is the minimum acceptable lead time between referral package submission and vessel arrival for CBP to act on a referral? | CBP cannot commit to a timeframe for acting on referral packages. |
| 41 | SOW | 6.0 Deliverables and Support | May vendors use a standardized template across referral packages, varying only the entity-specific evidence sections, or must each package be independently structured? | A standard template across referral packages from the same vendor would be preferred. |
| 42 | SOW | 6.0 Deliverables and Support | Will CBP provide vendors feedback on why specific referral packages were deemed not actionable (e.g., insufficient evidence, duplicate of existing enforcement action, resource constraints)? | Yes, CBP will provide this feedback during regularly scheduled meetings with each selected vendor. |
| 43 | SOW | 6.0 Deliverables and Support | When CBP declines to investigate a referral package due to "ongoing or previous enforcement actions," will that package still count toward the vendor's submitted volume for scalability measurement, even if it cannot be assessed for accuracy? | False positives and non-selected referrals are not included in the calculation for accuracy. |
| 44 | SOW | 6.0 Deliverables and Support | If a vendor submits a referral package that CBP chooses not to investigate due to resource availability (not due to quality deficiencies), will that package be excluded from accuracy calculations entirely? How will CBP distinguish resource-constrained non-investigations from quality-based rejections? | False positives and non-selected referrals are not included in the calculation for accuracy. Accuracy is measured as the percentage of CBP-actioned referrals that result in successful enforcement outcomes. The denominator is the number of referrals CBP chooses to investigate. |
| 45 | SOW | 6.0 Deliverables and Support | At Gate 1 (0–60 days), the accuracy threshold is 10%. Does this mean CBP expects to investigate and act upon at least 10% of submitted referral packages, or that 10% of investigated packages must result in prevention of entry or identification of additional duties? | Accuracy is measured as the percentage of CBP-actioned referrals that result in successful enforcement outcomes. The denominator is the number of referrals CBP chooses to investigate. 10% of the CBP-actioned referrals would need to result in successful enforcement outcomes. |
| 46 | SOW | 6.0 Deliverables and Support | If a vendor exceeds the scalability threshold (e.g., submits 3 packages/day during Gate 1 instead of the minimum 2/week), does excess volume carry forward or factor into evaluation for Gate 2 and Gate 3? | Negative. |
| 47 | SOW | 6.0 Deliverables and Support | Can CBP issue a stop-work order mid-gate (e.g., at Day 40) for failure to meet scalability thresholds, or will assessment occur only at the 60-day gate review? | CBP reserves the right to issue a stop-work order at any time during the base period, including mid-gate, if scalability or accuracy thresholds are not being met. |
| 48 | SOW | 6.0 Deliverables and Support | How quickly after the 180-day base period will CBP notify vendors whether Option Period 1 will be exercised? Is there a contractual timeline for that decision? | Decisions regarding Option Period 1 will receive notices of intent to exercise the next option period at least 10 days prior to the end of the base period contract. |
| 49 | SOW | 7.1.2 Basic Requirements | Section 7.1.2(h) states "Username/Password authentication is not allowed." What approved authentication mechanisms does CBP require for vendor systems — PIV/CAC cards, FIDO2/passkeys, certificate-based authentication, or other specific mechanisms? | There will be no connection to CBP Systems and solutions will not be behind CBP firewalls. |
| 50 | SOW | 7.1.3 Security Authorization | For the Security Authorization (Section 7.1.3), must vendors obtain a full ATO (Authority to Operate) before the base period begins, or is a System Security Plan (SSP) with ongoing assessment acceptable during the pilot phase? | No. During the base period, there will be no connection to CBP Systems and solutions will not be behind CBP firewalls. |
| 51 | SOW | 7.1.3 Security Authorization | Will CBP provide a Provisional Authorization or shared control inheritance for any GovCloud infrastructure it manages, or must vendors independently satisfy all FIPS 199 controls from scratch? | No. During the base period, there will be no connection to CBP Systems and solutions will not be behind CBP firewalls. |
| 52 | SOW | 7.1.4 Encryption Compliance Requirement | The SOW requires FIPS 197 (AES-256) and FIPS 140-2 validated cryptographic modules. Are FIPS 140-3 validated modules also acceptable, given that FIPS 140-2 is being phased out by NIST? | No. There will be no connection to CBP Systems and solutions will not be behind CBP firewalls. |
| 53 | Solicitation | 8.2 Intellectual Property | The CSOP solicitation notes that IP rights will be "negotiated prior to contract award." Can CBP provide its standard IP negotiation framework or baseline position so vendors can assess risk before investing in proposal preparation? | Generally, CBP seeks sufficient rights to use, reproduce, and modify deliverables for government use purposes, while vendors may retain ownership of pre-existing IP. Specific terms may be negotiated prior to award. Generally, CBP will use FAR 52.227-14 as framework for Data Rights. |
| 54 | Solicitation | 8.2 Intellectual Property | Will CBP retain rights to the AI models, algorithms, or risk-scoring methodologies developed or refined during the pilot, or only to the referral package outputs (data deliverables)? | Referral package outputs |
| 55 | Solicitation | 8.2 Intellectual Property | If a vendor's solution incorporates proprietary third-party data feeds or commercial AI models under license, how will CBP handle IP ownership of derivative outputs from those licensed components? | Consistent with the rights allotted in FAR 52.227-14, CBP generally seeks sufficient rights to use, reproduce, and modify vendor-derived insights, delivered data, and referral packages for government purposes, while vendors may retain ownership of proprietary commercial data and models. Specific terms will be negotiated prior to award. |
| 56 | Solicitation | 4.2 Evaluation Timeline and Phases | The solicitation states CBP "may select several viable candidates." Is there a maximum number of vendors that will be awarded base period contracts, or is the pool unlimited based on quality thresholds? | There is no predetermined maximum number of awards. CBP may select as many vendors at their discretion. |
| 57 | Solicitation | 4.2 Evaluation Timeline and Phases | Given this is a Non-FAR CSOP contract, what is CBP's anticipated timeline from Phase 1 solution brief evaluation to Phase 2 full proposal invitation? The solicitation does not specify this gap. | CBP does not have a specific timeline. Solutions are not evaluated on a comparative basis and will be evaluated on the basis of their own merits to the evaluation criterion set-forth in the solicitation. |
| 58 | Solicitation | 4.5 Technical Demonstrations/Oral Presentations | For the oral/technical demonstration (optional Criterion IV), what is the anticipated format — live system demonstration against sample manifest data, walkthrough of methodology, or both? | Vendors are encouraged to speak to the contents of their solution brief and provide any additional within the allotted timeframe that showcases their ability to meet the needs of the SOW. Vendors may be asked to address additional questions related to their solutions. |
| 59 | SOW / Solicitation | 2.0 Scope / Data Access Model | Would CBP consider proposals in which vendors deliver all required referral packages using vendor-sourced, legally obtained U.S. import data, without receiving CBP-provided pre-arrival data, provided that all other performance requirements (e.g., scalability, accuracy, and actionability of referrals) are met? | Yes |
| 60 | Solicitation | 3.0.1 Submission Window | Would the government please consider providing an extension of at least a month for vendors to provide an adequate response and sample referral package? | Negative. |
| 61 | SOW | 2.0 Scope | Would the government please provide sample data including example manifests so that vendors can create a sample referral package based on this example? | Negative. |
| 62 | SOW | Base Period of Performance Milestone Schedule | How much data will be provided to vendors during each 60-day Performance Measure Gate? | Approximately 1500 Manifest data entries will be provided M-TH |
| 63 | SOW | 6.0 Deliverables and Support | Section 6.0 defines actionable referral packages as containing “substantive supporting evidence (minimum of five pages).” Beyond this minimum, can the Government clarify what distinguishes a high-confidence referral package? Specifically, does CBP view structured analytic reasoning chains grounded in established intelligence tradecraft (e.g., ICD 203/206 sourcing standards, analysis of competing hypotheses) as a preferred form of supporting evidence relative to purely statistical or model-based risk scores? | Vendors are encouraged to submit their solutions for what constitutes a high-confidence illegal transhipment referral, including the rationale, AI methodologies, and data sources driving their analysis. |
| 64 | SOW | 2.0 Scope | The SOW identifies nine manifest data fields the Government will provide. To what extent does the Government consider these fields sufficient to support high-confidence illegal transshipment detection, and are vendors expected to fuse additional commercial or open-source data sources? | Vendors are permitted to use data from other sources. Vendors should be prepared to explain their data sources. |
| 65 | SOW | 2.0 Scope | Section 2.0 states CBP will make manifest information available no later than 72 hours before arrival. Can the Government clarify the expected daily volume of manifest records vendors will receive (e.g., hundreds, thousands, tens of thousands per day from higher-risk countries), and the delivery mechanism (API, secure file transfer, portal)? | Approximately 1500 records will be supplied daily M- TH via an e-mailed excel spreadsheet. |
| 66 | SOW | 6.0 Deliverables and Support | Can the Government provide guidance on the preferred format for referral package submission (structured template, narrative report, JSON schema, etc.) and the submission mechanism during the base period? | Referral Packages will be transmitted to CBP via e-mail. Referral packages should be submitted as a PDF (preferred) or word file. A proposed format of the referral package should be submitted with the submission of the solution brief. |
| 67 | Solicitation | 4.5 Technical Demonstrations/Oral Presentations | For invited technical demonstrations referenced in Section 4.5, what level of system maturity is expected (e.g., a fully operational production system as software, a prototype demonstrating representative outputs against sample data, or a software-enabled service)? | CBP does not have a preference; however, vendors should consider whether the readiness of their solution is conducive to the performance milestone thresholds set out in the SOW. |
| 68 | SOW | 7.1.7 Information Assurance | Section 7.1.7 requires deletion of all CBP data within 5 business days of contract end. Can the Government clarify whether referral package outputs containing CBP-derived analysis must also be deleted, or whether vendors may retain anonymized methodological artifacts for internal model improvement? | This may be negotiated prior to contract award. |
| 69 | SOW / Solicitation | 2.0 Scope / 2.0 Project Description | Section 2.0 indicates multiple awards are possible. During the base period, will vendors be assigned non-overlapping country or HTS scopes, or will multiple vendors receive identical manifest data and submit referrals against the same shipments? | The same manifest data will be given to all selected vendors. |
| 70 | SOW | 2.0 Scope | The SOW states CBP will provide manifest data for imports originating from countries it identifies as "higher risk for illegal transshipment." Will CBP provide vendors with that list of higher-risk countries at the outset of the pilot, or will it be provided on a rolling/dynamic basis? How frequently will it be updated? | A list of high-risk countries will be provided to vendors at contract award. CBP may update this list for all selected vendors at its discretion. |
| 71 | SOW | 2.0 Scope | In what format and via what transmission protocol will CBP deliver the 72-hour advance manifest data feed (e.g., EDI X12, EDIFACT, CSV, API)? Is there a data dictionary or schema available for the fields listed in Section 2.0 of the SOW? | Data will be transmitted by email in a password protected excel spreadsheet. |
| 72 | SOW | 2.0 Scope | Will CBP make historical manifest data available to selected vendors prior to the base period start date for the purpose of model training, calibration, or validation? If so, for what time period and in what format? | Negative |
| 73 | SOW | 2.0 Scope | Are vendors permitted — and encouraged — to supplement CBP-provided manifest data with their own commercially licensed third-party data (e.g., supply chain network data, corporate relationship graphs, port activity records, trade financing data)? Are there any restrictions on the types of external commercial data sources vendors may use to generate referral packages? | Yes. Vendors should be able to explain where the data comes from. |
| 74 | SOW | 2.0 Scope | The SOW requires that solutions operate without exposure to CBP's law enforcement-sensitive targeting models. Does this restriction also apply to receiving any historical enforcement outcome data (e.g., past seizures, penalty cases) for the purpose of model training or validation? If not, what enforcement outcome data, if any, can CBP make available? | Negative |
| 75 | SOW | 6.0 Deliverables and Support | Is there a required format or schema for referral package submissions, or will CBP accept vendor-defined formats provided the minimum content requirements (5 pages of substantive evidence, in-transit identification) are met? | There is not a required format. A sample referral package should be submitted with the submission of the solution brief. |
| 76 | SOW | 6.0 Deliverables and Support | What is CBP's anticipated turnaround time for providing feedback on whether a submitted referral package is considered actionable and/or led to an enforcement action? This directly affects vendors' ability to iterate and improve accuracy within each 60-day performance gate. | Feedback will be provided during routine meetings to be held on a weekly or biweekly cadence. |
| 77 | SOW | 6.0 Deliverables and Support | For accuracy measurement, the SOW states that only referral packages CBP chooses to investigate will be counted. Will vendors receive written feedback on packages CBP declines to investigate, and if so, will CBP indicate the reason (e.g., duplicate of existing case, resource constraints, insufficient confidence level)? | Feedback will be provided during routine meetings to be held on a weekly or biweekly cadence. |
| 78 | SOW | 3.0 Period of Performance | The 180-day base period is described as "no-cost" to the government. Can CBP confirm that vendors are expected to bear all costs during this period — including data licensing, infrastructure, and labor — with no reimbursement or government-furnished resources beyond the manifest data feed? | Yes, vendors are expected to bear all costs during the no-cost base period, including data licensing, infrastructure, and labor. CBP intends to provide only the manifest data feed. |
| 79 | Solicitation | 2.0 Project Description | Is the $1,250,000 price cap per option period intended to cover all costs (labor, data, infrastructure) for the full option period, or does it represent a ceiling on the government's fee for vendor services exclusive of government-furnished data and resources? | The $1,250,000.00 price cap per option period is the total value the Government will allow for the option periods, exclusive of any government-furnished data or resources. Proposed pricing shall fit within those value parameters. |
| 80 | Solicitation | 3.2.1 Content of Solution Brief | Are teaming arrangements or prime/subcontractor structures permitted under this CSOP? If so, must the prime contractor hold the AI capability, or may a data and supply chain traceability platform serve as the prime with an AI technology partner as a subcontractor? | Teaming arrangements and prime/subcontractor structures are permitted. The prime contractor does not have to hold the AI capability, but must ensure the team collectively meets all requirements. |
| 81 | Solicitation | 8.2 Intellectual Property | Section 8.2 defers IP terms to negotiation at Phase II. Can CBP provide any preliminary guidance on its typical posture with respect to: (a) vendor-derived insights and referral packages produced during the pilot, and (b) the underlying proprietary commercial data and models vendors bring to the engagement? | Consistent with the rights allotted in FAR 52.227-14, CBP generally seeks sufficient rights to use, reproduce, and modify vendor-derived insights, delivered data, and referral packages for government purposes, while vendors may retain ownership of proprietary commercial data and models. Specific terms will be negotiated prior to award. |
| 82 | SOW | 6.0 Deliverables and Support | Would CBP consider referral packages that incorporate voluntarily-disclosed supply chain data from importers, exporters, freight forwarders, or other supply chain participants — data collected outside of the government's manifest feed — to be more probative or higher-confidence than packages derived from manifest data alone? How would CBP evaluate the evidentiary weight of such voluntarily-submitted data in its enforcement decisions? | CBP welcomes a wide range of private sector solutions for identifying Illegal transshipment risk. |
| 83 | SOW | 2.0 Scope | Are vendors permitted to directly engage importers, freight forwarders, customs brokers, or other supply chain participants as part of the pilot — for example, to solicit voluntary data sharing in exchange for risk profile benefits — or must all data collection occur through CBP-provided channels? | Vendors are able to utilize data outside of what CBP provides. Vendors should be prepared to explain where the data originated. |
| 84 | SOW | 2.0 Scope | If a vendor builds a participant network in which supply chain entities voluntarily disclose detailed shipment-level data (e.g., purchase orders, supplier identities, production facility locations, bills of lading beyond what appears in the manifest), would CBP be willing to treat demonstrated participation in such a network as a mitigating factor that lowers an entity's assessed risk profile? In other words, is there a mechanism for "voluntary transparency" to reduce enforcement scrutiny? | The Illegal Transshipment Pilot is not intended to explore benefits for companies who provide information indicative of low illegal transshipment risk. |
| 85 | SOW | 2.0 Scope / Office of Field Operations | CBP's C-TPAT program already creates a tiered risk framework for known, vetted supply chain partners. Would vendor risk models that leverage or cross-reference C-TPAT membership — as a baseline signal of supply chain legitimacy — be viewed favorably during evaluation? And could vendors work with CBP to incorporate C-TPAT status as a risk-reducing variable in referral package scoring? | The Illegal Transshipment Pilot is not intended to explore benefits for companies who provide information indicative of low illegal transshipment risk. |
| 86 | SOW | 2.0 Scope / Privacy | If a vendor's approach involves collecting supply chain data from private participants, are there any legal, privacy, or data-sharing constraints the government is aware of that vendors should address in their solution brief — for instance, around the use of voluntarily-disclosed commercial data in a federal enforcement context? | Negative. Vendors are responsible for their agreements with third party or sub-vendors. Vendors should explain their data sources. |
| 87 | SOW | 2.0 Scope | For entities that participate in a vendor's voluntary data collection program and demonstrate verifiable supply chain transparency, would CBP be open to a feedback mechanism that signals to the vendor (and transitively to the participant) that their risk profile has been assessed as low? This would create an incentive structure for industry participation and could drive broader adoption of the data-sharing model over time. | The Illegal Transshipment Pilot is not intended to explore benefits for companies who provide information indicative of low illegal transshipment risk. |
| 88 | General | N/A | Did CBP procure similar kind of pilots in the past, which are related to illegal transshipment identification. If yes, Will CBP please confirm the name of the incumbent contractor(s) and the contract number(s)? | CBP does not currently have contracts that primarily support this effort. |
| 89 | General | N/A | Is CBP able to provide ODC costs for the previous pilot contract? In case of the current pilot, should the final quotation include the ODC costs (operational, license, usage costs)? | Vendors shall propose pricing specific to the nuances of their solution. |
| 90 | General | N/A | Will there be a Government-assigned ISSO on this contract? | Negative |
| 91 | General | N/A | Will there be any documentation, processes, or license transferred over to the new contractor(s)? | Negative |
| 92 | General | Page 5 | "CBP plays a critical role in the enforcement of trade regulations and the collection of customs revenue, positioning itself as the nation’s second largest revenue collection agency." Will the government be able to provide a high-level systems overview of the existing IT system that has been effectively operating at the scale suggested above? Can you kindly include Technical Architecture, Concept of Operations, Technology Stack etc.,? | As a CSOP, CBP is looking for an innovative commercial solution to identify illegal transshipment before goods are released into commerce. There is not a current solution that is solving this problem set. |
| 93 | Solicitation | 3.2.1 Content of Solution Brief | Vendors will depend on CBP to provide the seed information on the shipments. When CBP asked vendors to define "The discrete sources of information that will be used to generate referral packages and the AI-driven methodologies used to assess illegal transshipment risk.", are they asking the vendors about other supporting sources of information apart from the seed data? | Yes. |
| 94 | Solicitation | 4.2 Evaluation Timeline and Phases | The technical content from "Phase 1 (Solution Brief - NTE 20 pages)" would be carried forward to "Phase 2 (Full Proposal - Section 2: Proposal Solution)". Essentially, the government/CBP is asking the vendor to provide additional information in Full Proposal phase (pricing, risks, issues, additional support, project deliverables and project schedule etc.,). Can government validate this assumption? | Yes, CBP confirms that the Full Proposal phase will build upon the Solution Brief and include additional information such as pricing, risks, issues, deliverables, and schedule. |
| 95 | Solicitation | 4.5 Technical Demonstrations/Oral Presentations | What kind of roles is the government expecting in an Oral Presentation? Sometimes, the government expressed explicit interest in having technical folks rather than BD folks. Can CBP clarify if there are any restrictions to type of roles who would be responsible to do this Oral Presentation? | CBP prefers that technical subject matter experts participate in Oral Presentations. The team should include personnel who can address technical, operational, and management aspects of the proposal. If invited to an Oral presentation or Technical Demonstration, further detail will be provided. |
| 96 | Solicitation | 4.5 Technical Demonstrations/Oral Presentations | Could CBP confirm that they envision contractors conducting interviews both in-person and online (e.g., videoconference)? For the in-person interviews, does CBP anticipate any travel being needed? | Oral pitches will be conducted via videoconference |
| 97 | Solicitation | 7.2 Payment and Invoice Instructions (APR 2014) | Should invoices be submitted on a monthly basis in the Option 1 period? Would be Option 1 & Option 2 periods based on a Firm-Fixed Price contract type? | The methodology for invoice submission will be mutually agreed upon depending on the model of the solution and the deliverables to be provided, which could be on a monthly basis. Both Option 1 and Option 2 periods will be Firm-Fixed Price, as stated in the solicitation. |
| 98 | Solicitation | 5.4 Price Information | Can CBP provide a excel template for offerors to provide the price information. Apart from the milestone schedule what other information should be included in the business proposal? | The Government expects solutions to be unique from each other, therefore, the Government does not have a prescribed format for pricing submission. |
| 99 | General | N/A | Can the government confirm that invoices should be submitted monthly alongside the Monthly Progress Report? | Invoices may be submitted monthly and should be accompanied by the Monthly Progress Report, however invoice frequency may be negotiated with the potential awardees depending on the circumstances of the solution. |
| 100 | Solicitation | 8.1 System for Award Management (SAM) Registration | "If Contractor is authorized to make subawards under this award, Contractor:..." Should the contractor seek permission from CBP before making subawards under this award? | Contractors should notify CBP and seek approval prior to making subawards under this award, as required by the solicitation. |
| 101 | General | N/A | Considering the FFP contract type, would the government consider removing all the requirements for including all indirect and allow only fully burdened price and hours for a total price? | CBP requires a fully burdened Firm-Fixed Price. All indirect costs should be included in the total price. |
| 102 | General | N/A | Due to the FFP nature of this contract, can the government confirm that LOE and cost for all individual personnel by task is not required for submission? | For Firm-Fixed Price contracts, CBP does not require a detailed level of effort or cost breakdown by individual personnel or task unless specifically requested in the solicitation. CBP will be required to make a fair and reasonable price determination for each solution, so vendors should be prepared to prove how pricing is considered fair and reasonable. |
| 103 | Solicitation | 1.1 Background | "In Fiscal Year 2025, CBP successfully collected $216.7 billion in duties, taxes, and fees, continuing a legacy of robust enforcement that has led to the collection of 99.5% of all customs tariff revenue owed to the U.S. since 1992." How much of the $216.7B is collected as a result of identifying illegal transshipments? This is to understand the reach of this important business process that identifies illegal shipments. | CBP declines to respond to this question. |
| 104 | Solicitation | 3.2.1 Content of Solution Brief - Section 3 – Sample Illegal Transshipment Referral Packages | Can CBP provide guidance or examples of what constitutes a high-quality vs low quality, “actionable”/“inactionable" referral packages beyond minimum requirements? | Vendors are encouraged to submit their solutions for what constitutes a high-confidence illegal transhipment referral, including the rationale, AI methodologies, and data sources driving their analysis. |
| 105 | Solicitation | 3.2.1 Content of Solution Brief - Section 3 – Sample Illegal Transshipment Referral Packages | Should referral packages focus on individual shipments, entities (e.g., shippers/consignees), or broader networks of related trade activity? | At a minimum, referral pacakges should trace to shipments that the vendor believes are involved in illegal transshipment. CBP welcomes additional information and risk indicators about specific entities and broader networks. |
| 106 | Solicitation | 3.2.1 Content of Solution Brief - Section 3 – Sample Illegal Transshipment Referral Packages | What level of feedback will CBP provide (e.g., binary outcome vs detailed rationale)—particularly for referrals that are not investigated or not actioned—and at what cadence? | Feedback will be provided during routine meetings to be held on a weekly or biweekly cadence. |
| 107 | General | N/A | What is the plan for transition at the end of Option 2 period? Will CBP be able to absorb all the AI product costs, cost of operations etc.,? | The results of this technology demonstration may inform an enterprise-wide, competitive procurement for AI-driven illegal transshipment detection tools. Any follow-on acquisition or scaling will be determined based on the outcomes of the pilot and CBP’s operational needs. The procurement strategy for a follow on acquisition after this pilot cannot be determined at this time. |
| 108 | SOW | 2.0 Scope | "To support this requirement, vendors may choose to receive the below manifest information for imports originating from countries that CBP identifies as being higher risk for illegal transshipment. CBP will make manifest information available to vendors no later than 72 hours before imports are expected to arrive in the U.S." - Is it safe to assume that CBP would provide the manifest information to only vendors who are finally awarded the contract? Is it possible to get access to a sample dataset along with a Data Dictionary for the purposes of solutioning for this Pilot before the award? | Correct. Manifest data will only be provided to awarded vendors. CBP will not provide a sample dataset or data dictionary prior to award. |
| 109 | SOW | 2.0 Scope | Are certain industries, Harmonized Tariff Schedule codes prioritized for this pilot beyond “high risk countries”? | Negative. |
| 110 | SOW | 2.0 Scope | "What level of data completeness and quality should vendors expect (e.g., missing fields, inconsistent shipper names)? What are the expected formats, frequency, and delivery methods (e.g., API, batch files) for manifest data provided ~72 hours pre-arrival? Will historical manifest or labeled enforcement data be made available? Are there additional datasets CBP may provide beyond manifest data (e.g., enforcement outcomes, rulings, trade data)?" | Data will be transmitted by email in a password protected excel spreadsheet. CBP does not anticipate providing historical data sets nor does it anticipate providing data beyond whats stated in the SOW. |
| 111 | SOW | 2.0 Scope | Are vendors permitted to augment CBP-provided data with third-party or commercially available datasets? E.g. trade route data, tariff data | Yes |
| 112 | SOW | 6.0 Deliverables and Support - Base Period of Performance Milestone Schedule | Are vendors penalized for false positives, or only evaluated on successful detections? | Accuracy is measured as the percentage of CBP-actioned referrals that result in successful enforcement outcomes. The denominator is the number of referrals CBP chooses to investigate. False positives and non-selected referrals are not included in the accuracy calculation. |
| 113 | SOW | 6.0 Deliverables and Support - Base Period of Performance Milestone Schedule | How will CBP normalize accuracy given that only referrals selected for investigation are included in performance evaluation? | Accuracy is measured as the percentage of CBP-actioned referrals that result in successful enforcement outcomes. The denominator is the number of referrals CBP chooses to investigate. False positives and non-selected referrals are not included in the accuracy calculation. |
| 114 | General | Related to Transition | "How does CBP envision integrating successful solutions into enterprise-wide targeting systems? What would differentiate a vendor for long-term partnership beyond the pilot?" | CBP has not made any decisions about how it envisions intergrating successful solution into enterprise-wide targeting systems. |
| 115 | SOW | 7.1.2 Basic Requirements | What are the "Legacy air gapped non-integrated systems"? Is CBP saying that vendor IT systems cannot connect to internet over the Wi-fi? | Not applicable |
| 116 | Solicitation | 4.2.1 Phase 1 Evaluation & 5.5 Phase II Evaluation | Would CBP please share an example of a filled-out full scorecard (for a sample vendor) with the offerors? | Please Refer to the Evaluation Instructions in the Solicitation document. That document details how vendors will be evalauted. |
| 117 | SOW | 2.0 Scope | Would CBP please describe the nature or types of data they will share? Does CBP have an existing data management system they prefer to continue with? If so, where is the system located and what types and amounts of data stored? If CBP does not have a preferred cloud or system, please state this preference as well. | CBP will transmit manifest data via emailed password protected excel files. |
| 118 | SOW | 3.0 Period of Performance | Is CBP open to automation and business process improvements on existing reports using latest software and technology? Is new development considered in-scope on this contract? | No. CBP is looking for vendors to submit referral packets for illegal transshipment risk. |
| 119 | General | N/A | What existing APIs will the offerors have access to once the contract is awarded? | None. Referral Packets and manifest data will be sent via e-mail. |
| 120 | SOW | 2.0 Scope | "Vendors will be given an opportunity to prove out the scalability and accuracy of their illegal transshipment solutions over the course of a no-cost, 180-day base period of performance." - Each of these tasks highlights a unique business process. Would CBP please provide a high-level business process diagram that helps the offeror understand the stakeholders involved and how they would interact with others? | No. Each vendor will work independently submitting their own referral packages for CBP to review. The intent of this CSOP is for vendors to identify potential illegal transshipment in shipments destined for the USA and submit those potentials with evidence to CBP as referral packets. |
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