Financial Forensics Accounting Training SOW 191NLE23Q0011.pdf

Bureau of International Narcotics and Law Enforcement Affairs (INL)

U.S. Embassy Nassau

Statement of Work

Financial Forensic Accounting Training and Assistance

191NLE23Q0011

U.S. Department of State INL Nassau Financial Forensic Accounting Training and Assistance

SECTION 1

SOLICITATION CONSIDERATIONS

1.1 SYSTEM FOR AWARD MANAGEMENT

This solicitation requires registration with the System for Award Management (SAM) prior to award, pursuant to FAR 4.1102 and other applicable regulations and guidelines. Information can be found at www.sam.gov.

1.2 TRADE AGREEMENTS ACT (19 U.S.C. 2512(A)) (TAA)

Pursuant to the Trade Agreements Act (19 U.S.C. 2512(a)) (TAA), Federal acquisitions of supplies may be made only from offerors that shall supply products of an eligible country under any of the free trade agreements entered into pursuant to the TAA. An article is considered a product of a country only if it is wholly a product of that country or if it has been, substantially transformed, in that country into a new and different article of commerce with a name, character, or use distinct from that of the original article(s). Note that any item that is a discreet article as it is sold in commerce, regardless of its ultimate function or use, cannot be considered, substantially transformed, and based solely on its integration into IT or other systems

1.3 UNAUTHORIZED DISCLOSURE

The Contractor and its employees shall exercise the utmost discretion concerning all matters relating to their duties and functions. They shall not communicate to any person any information known to them by reason of their performance of services under this contract, which has not been made public, except in the necessary performance of their duties or upon written authorization of the Contracting Officer.

All documents and records (including photographs) generated during the performance of work under this contract shall be for the sole use and become the exclusive property of the U.S Government.

Furthermore, no article, book, pamphlet, email, recording, broadcast, speech television appearance, film or photograph concerning any aspect of work performed under this contract shall be published or disseminated through any media without the prior written authorization of the Contracting Officer.

These obligations do no cease upon the expiration or termination of this contract. The Contractor shall include the substance of this provision in all contracts of employment and in all subcontracts hereunder.

See FAR 3.104 for additional information.

(Rest of Page Intentionally Left Blank)

SECTION 2 (Instruction to Offerors)

INSTRUCTIONS, CONDITIONS, AND NOTICES TO OFFERORS/RESPONDENTS

SUBMISSION INFORMATION PERTAINING TO REQUEST FOR QUOTE

2.1 INFORMATION TO CONTRACTOR

Contractors are reminded that information furnished under this Request for Quote (RFQ) may be subject to disclosure under the Freedom of Information Act (FOIA). Therefore, all items that are confidential to business or that contain trade secrets or proprietary or personnel information shall be clearly marked. Marking of items shall not necessarily preclude disclosure when Department of State (DOS) determines disclosure is warranted by FOIA. However, if such items are not marked, all information contained within the submitted documents shall be deemed releasable.

2.2 QUESTIONS CONCERNING SOLICITATION

Offerors are warned against contacting any INL personnel other than the Contracting Officer and Contract Specialist prior to award of the Contract resulting from this RFQ. If such a contact occurs and found to be prejudicial to competing vendors, the vendor making such a contact may be excluded from award consideration.

No information concerning this RFQ shall be provided in response to telephone calls. All such requests shall be submitted in writing to the Contracting Officer and Contract Specialist.

Submit Questions by:

• 5:00 P.M. (local Washington D.C. time) on the following date: 01 February 2023

2.3 NOTICE OF SAM.GOV SYNOPSIS CLOSING DATE AND TIME

All offers shall be submitted to the designated Government Representative via email.

Any communications in reference to this RFQ shall cite the reference section title and page number, and directed to the following individuals:

Name: Mohan N Krishnakumar Title: Contracting Officer E-mail: KrishnakumarM@state.gov

Name: Katina Russell Title: Contracting Officer Representative E-mail: RussellKV@state.gov

Closing Date and Time:

• 5:00 P.M. (local Washington D.C. time) on the following date: 15 February 2023

2.4 CONTRACTOR RELATIONSHIPS

The Department of State (DOS) encourages the use of subcontractors. In addition, the Department requires that any potential Organization Conflict of Interest be identified in the proposal to ensure proper firewalls established prior to award.

2.5 MULTIPLE PROPOSALS/ALTERNATIVE SOLUTIONS

Contractors shall not submit, nor shall the Government accept or evaluate, multiple proposals offering alternative solutions. Contractors shall not submit, nor shall the Government accept or evaluate, multiple solutions within one proposal.

2.6 PERIOD OF ACCEPTANCE OF OFFERS

Contractors shall agree, if the proposal is accepted within ninety (90) calendar days (unless a greater period is inserted by the contractor) from the date specified in the solicitation for receipt of proposals, to furnish any or all of the requirements upon which prices are proposed at the price set opposite each item, performed and/or delivered at the designated point(s) within the time specified.

2.7 SPECIFIC SUBMISSION INSTRUCTIONS

Vendors shall limit the number of pages to no more than fifteen (15), 12 Point Font, Times New Roman, pdf.

Statement of Work (SOW)

I. PROGRAM BACKGROUND

Mission of the U.S. Department of State: The U.S. Department of State is the lead institution for the conduct of American diplomacy and the Secretary of State is the President’s principal foreign policy advisor. The Department of State’s mission is to advance U.S. national security interests, fight terrorism, protect U.S. interests abroad, and implement foreign policy initiatives that build a freer, prosperous, and secure world.

Mission of the Bureau of International Narcotics and Law Enforcement Affairs: INL is under the Under Secretary for Democracy and Human Rights (J) and works to keeps Americans safe at home by countering international crime, illegal drugs, and instability abroad. INL helps countries deliver justice and fairness by strengthening their police, courts, and corrections systems. These efforts reduce the amount of crime and illegal drugs reaching U.S. shores.

The main partner of INL in The Bahamas is the Royal Bahamas Police Force (RBPF). INL Nassau aims to help the RBPF, along with the Financial Intelligence Unit (FIU), and the Director of Public Prosecutions (DPP), increase their financial investigation capabilities and rate of successful prosecutions of financial fraud, money laundering, and corruption. This includes training on new investigative skills to trace and examine financial transactions, advanced use of case organization and presentation software, and core competencies in rules of evidence and criminal procedure.

INL’s training effort will be structured to improve core and specialized skills needed for the RBPF’s current caseload and will encourage proactive lines of inquiry for complex investigations. The training program will assist in the building of specific real time cases and reinforce bilateral U.S.- Bahamas law enforcement relationships and cooperation.

II. SCOPE OF WORK

The scope of this project includes the development and delivery of comprehensive Financial Investigative/Analysis Courses as well as in-person mentoring and assistance in case preparation from highly experienced subject matter experts. Delivery of the training/mentoring/case preparation program (hereafter referred to as the training session) will be provided in three-week increments, three (3) times per year during the yearlong period of performance. Each training session will consist of one (1) week of contractor-developed training, one (1) week of in-person mentoring and/or assistance with case preparation based on actual cases awaiting adjudication, and one (1) week of remote mentoring and assistance. The course sessions shall be designed to equip Bahamian analysts, police, and prosecutors with the tools, skill sets, and knowledge necessary to investigate, compile admissible evidence, and prosecute cases involving public corruption, money laundering, and proceeds of crime.

The Contractor shall provide instructor staff on a /Host Nation-provided site in Nassau, The Bahamas for one of the three training courses, the Contractor shall provide instructor staff in Nassau and shall provide the training venue/site in Nassau for one of the three trainings, and the Contractor shall provide instructor staff to host the trainees in Florida and shall provide the training venue/site in Florida for one of the three trainings.

The Contractor will also assist top-performing officers in sponsoring the cost of professional certification in financial crimes detection and prevention and/or anti-money laundering.

The contract will contain two (2) year-long option periods to allow for additional courses and case development, as training needs arise.

III. PERIOD OF PERFORMANCE

The period of performance will be one (1) year from contract award, with two (2) option years with three training sessions offered each year.

IV. EQUIPMENT

The U.S. Embassy will provide IBMi2 Analyst notebook, iBase, and iBase Designer.

V. PLACE OF PERFORMANCE

The training sessions are to be conducted at an RBPF facility in Nassau, The Bahamas, in a contractor-provided facility in Nassau, The Bahamas, and in a contractor-provided facility in Florida, United States

VI. PROGRAM REQUIREMENTS

The Contractor shall use actual, current cases to develop curriculum, to teach, to demonstrate through mentorship and assistance in case preparation, and to provide guidelines for effective delivery of training courses.

The Contractor will receive existing training modules which have been delivered to the FCIB and other stakeholders as a suggested starting point, to modify as needed due to changes in trends or law and to reinforce and build on prior concepts and training, to meet the requirements of this SOW.

1. Curriculum Development Requirements (3 training sessions, each 1 week long; 3 weeks of in-office mentoring, each 1 week long; 3 weeks of remote mentoring, each 1 week)

The Contractor shall develop the curriculum to conduct trainings for the Royal Bahamas Police Force, Directorate of Public Prosecutions (DPP), and the Financial Intelligence Unit (FIU) officials, focusing on the topics outlined in this SOW. The curriculum must be aligned with the reality of situations, laws, and experiences specific to The Bahamas, and incorporating internationally accepted standards. The Contractor shall provide experts that will be responsible for training and mentoring on the topics listed below, focusing on developing a high level of knowledge in intelligence analysis, as well as investigation and case preparation. One group of twenty (20) investigators, analysts, and prosecutors shall attend each training course. The primary components to be developed shall include but are not limited to:

• Money Laundering Trends

• Investigative Tools for Financial Crimes

• Legal Case Preparation (to include Bahamian Evidence Act and Criminal Procedure Code)

• Digital Evidence

• IBM i2 platform software use in case-mapping

• Legal Cooperation

• Financial Assessment Modeling

• Sources of Information

• Trial Preparation and Testifying

• Asset Forfeiture

• Bank-scan use or equivalent software

• Emerging technologies, to include tracing cryptocurrency and peer-to-peer payment applications

Course Requirements

• Creation of guidance for the RBPF, DPP, and FIU officials on how to collect, evaluate, and compile financial information to combat and overcome serious financial fraud, money laundering, and corruption.

• Design and develop all materials to be used in the trainings. Training Materials include PowerPoint presentations, manuals, handouts, group and individual activities, and any other materials deemed necessary by the Contractor. The Contractor shall provide the COR with a list of reference materials used for curriculum development.

• Provide mentoring and assistance on investigative cases to practitioners from the RBPF, FIU, and DPP who take part in classroom training sessions. Provide own equipment including a computer, PowerPoint projector, and other presentation and course materials as needed per the requirements of the curriculum for all course lectures.

• Course documents shall be submitted to the COR for approval in accordance with deliverable timetable.

• The proposed curriculum shall include relevant case studies and applicable exercises specific to The Bahamas, transnational crime, Bahamian law enforcement regulations, and the Bahamian judicial system.

• Instruction on formal and informal legal cooperation (timing of requests, use in court, and processes).

• Pre-training and post-training testing assessments (the latter to cover the same concepts with new questions) to be conducted to understand if gains in knowledge through training events.

• Training should include one familiarization session to prosecutors on i2 charts prepared by RBPF. Familiarization session should include reference to models, graphs, charts, diagrams, computer reconstruction and other established court exhibits for prosecutors to compare and contrast with i2.

• Organize 1-3 strategic U.S. or regional study visits as determined by instructors in consultation with partners (i.e., FIU to FinCEN, FCIB to DEA, DPP/AG to OIA, etc.).

• Reference guides (pocket or electronic) for Elements of the Offense or forfeiture provisions of POCA – number and content determined by trainers in consultation with RBPF.

Case Preparation/Mentoring Requirements

• Instructors to serve as resource persons for remote or in-person questions related to the collection, evaluation, and compilation of financial information specific to current/on-going RBPF investigations.

• Timely remote or in-person case mentoring plan of action assistance built into the project for OPBAT-related drug seizures involving cash or property (i.e., cash seized in suitcases at airport during a drug enforcement operation).

• Support the development of investigations into matters that could be used in a Bahamian court.

• Work with RBPF to identify and mentor senior officers (ASP rank or higher) to apply skills for proactive drug money laundering investigations or other complex investigations depending on types of crimes at hand.

• Identify regional or international certificates and assist (2-3) senior officers in successful completion of training credits (through preparatory assistance), arranged through project funds per year

• Provide recommendations on standard operating procedures for investigators, prosecutors, and financial intelligence unit.

• Identify ways to reinforce the ability of investigators to prepare all components of a financial investigation to be used in the court of law.

• Facilitate meetings and interactions between police investigators and prosecutors.

• If sufficient stakeholder buy in, convene quarterly meetings between bank compliance officers, SCB, FIU, FCIB, and U.S. law enforcement to discuss general financial crime observations and trends.

Deliverables Due Date: NLT 30 business days from contract award Recipients: Electronically to the CO, COR

• Consult with INL Nassau about project and local partners prior to course development

• Develop a course curriculum to teach the ‘primary components’ listed in section V.1. of

SOW, above.

• Develop a schedule for the instructors to follow while teaching the course.

• Write tests for each training event: one (1) pretest to be administered before the course is taught (to assess baseline knowledge), and one (1) final test to be administered after each training event is completed. The post-training questions should cover the same concepts as the pre-test questions, with different formulations.

o Analysis of results for each training event should inform future training techniques used and training content delivered. A summary of results for each training event should be provided to the COR (see section V.2 below).

• Develop PowerPoints to be used during the course.

• Write guides, handouts, group and individual activities, and any other course materials to be distributed to the students during the course.

o Prior to the beginning of the course print all handouts to be used during the course.

2. Reporting Requirements

During each of the training courses, the Contractor shall maintain open, timely, and effective communications with the COR, resulting in a relationship that shall proactively address any potential issues.

Deliverables Due Date: As required; see below Recipients: Electronically to the CO, COR

• Substantive quarterly reporting on mentoring/advising activities during the prior three months to include:

o Summary of assistance related to case investigations under Proceeds of Crime Act (POCA) and OPBAT-related drug seizures involving cash or property o Suggested modifications to existing practices or new policies that should be developed to support internationally-accepted best practices o Other topics that affect program delivery

• Submit an action report after each training is completed. Each report shall be 2-3 pages in length and shall include:

o Names of practitioner completing the course o Training concepts delivered o Summary of pre- and post-testing results o Instructor’s assessment of practitioner commitment to implement the material

• Submit a final report at the end of the contract. The report shall be 6-9 pages in length and shall be submitted to the COR within 20 business days of the conclusion of the final year of the project. The report shall include:

o Assessment of the strengths of the FCIB, including a description of the skills of top performing officers in terms of ability to conduct major crime investigations o Detailed information demonstrating the gains through the program, such as case success, changes in practice, and/or new investigative skills to trace and examine financial transactions o Problems encountered o Recommended follow-up activities for U.S. Embassy personnel to consider

VII. STAFFING REQUIREMENTS

The Contractor shall be responsible for recruitment of qualified Curriculum Writer/Instructor candidates that meet or exceed the minimum qualifications set out below. INL reserves the right to review recruitment materials and outreach efforts. The Contractor shall be responsible for creating the necessary composition for the curriculum development team and instructor team.

Curriculum Developer Team Requirements:

• The curriculum development team shall be composed of highly experienced state, federal or local law enforcement police officers/agents and analysts, with at least 15 years of experience and must include assignments to counter-drug law enforcement intelligence units or groups. Military police or military intelligence or intelligence community experience alone (without civilian federal, state, or local law enforcement-intelligence experience) in conducting similar or related activities, does not qualify.

• The curriculum development team shall include subject matter experts (SME) on forensic accounting and The Bahamas and the Caribbean including personalities, banks and financial organizations, and financial routes and modus operandi.

• The curriculum development writer shall have experience in writing and developing training curriculum for government and/or law enforcement courses/workshops/trainings.

Instructor Requirements:

• A ratio of one instructor per 20 students is required. The training team may be comprised of between two to three instructors on site. Instructors may rotate throughout the training.

• Instructors must have the ability to work independently and function effectively as part of a team in a dynamic joint environment.

• The instructors’ team shall be composed of highly experienced former or current U.S. federal, state or local law enforcement-intelligence analysts and/or special agents, police officers, or task force agents-officers) assigned to intelligence groups and performing intelligence related duties.

At least one member of the instruction team must be an experienced former or current Drug Enforcement Administration Financial analyst.

• All Instructors must have extensive financial investigation experience including assessing, mentoring, and training in:

• Areas of foreign and domestic law enforcement-intelligence activities involving support to complex, multi-jurisdictional and multi-national investigations, including drug enforcement, money laundering, financial crimes, working closely with ‘vetted’ or specialized foreign prosecutors and foreign judicial processes.

• Areas of judicially approved telecommunications intercepts, undercover operations, human source recruitment and handling, human source network management and administration, raw information and evidence collection, processing-handling and analysis, formulation of target packages, and other intelligence work.

• All instructors shall have experience in all-source intelligence cycle processes with an emphasis on money laundering, public corruption, and financial crimes. These intelligence cycle processes shall also include knowledge of case preparation with an emphasis on evidence collection, presentation, and court-room presentation.

• Instructors must be competent in the application and understanding of the intelligence process to compile, collate, analyze, produce, and evaluate intelligence and provide subject matter expertise in supporting a variety of tasks and disciplines.

• Instructors must have experience using and teaching bank-scan and IBMi2 software platform.

• Instructors must have competence in providing instruction on the analysis, assessment, production, and dissemination of all-source integrated intelligence on corruption, and the links to criminals.

• Instructors must be competent in writing and producing counter-drug intelligence summaries, estimates, targeting packets, and visual graphic presentations to convey the current counter-drug common operating picture derived from multi-discipline intelligence sources.

• Instructors must have knowledge of The Bahamas and money laundering and criminal proceeds flow from The Bahamas, including local and regional banks, local lending and financial organizations and institutions, organizations and trafficking routes, and modus operandi.

Instructors must be familiar with United Kingdom or Bahamas legal system and must have prior experience in the Caribbean region.

• The Contractor shall submit for approval the trainers. The Contractor shall be responsible for recruitment of qualified candidates that meet or exceed the minimum qualifications. In addition, if the Contractor replaces any trainers of staff during any period of this contract, the Contractor must recruit and submit to the COR for review, final approval, and country clearance as replacement candidates who meet the qualifications as outlined in this SOW.

• All instructors must hold at least Secret Level security clearances.

• All instructors must have worked for U.S. or UK law enforcement or legal environment for a minimum of ten (10) years.

VIII. Travel The Contractor shall be responsible for providing Airfare, Per Diem (e.g., Lodging & M&IE), and Airport transfers in The Bahamas for the trainers while in country. If needed, the U.S. Embassy in Nassau can assist with hotel reservations for each police trainer at the government rate. The Embassy will be responsible for all travel costs associated with Bahamian practitioners.

IX. DELIVERABLE MATRIX

The table below identifies scheduled due dates (To be determined at award), deliverable alignment with the objectives listed above in Section V and the type of review, classified as Delivery Standard (DS). Deliverables are identified as required documents that are necessary for INL review and approval.

The numbers of days listed in the deliverable schedule are business days. All deliverables will be accepted according to the deliverable review and acceptance guidelines. Please note that update cycles will repeat until Offeror deliverables are accepted.

Once awarded, the Contractor shall provide the Deliverable Schedule dates for Government approval.

Deliverables must be provided according to a schedule that meets the Government’s availability for review. Only the Contracting Officer’s Representative (COR) or Contracting Officer (CO) can formally accept work products and or deliverables.

Delivery Standard (DS)

• 10 business days for INL to review and comment

• 5 business days for Contractor to respond with updates

• 5 business days for INL to accept/reject updates

The Contractor shall provide the deliverables identified in the following Deliverables list in accordance with the schedule approved by the Government. The Contractor may be required to provide additional deliverables either upon Government request or as proposed by the Contractor. In addition, the Contractor shall update deliverables as necessary or as directed. All documentation must be free of grammar and typographical errors.

Line SOW Section Deliverables Format and

Content Recipient(s)

Copies Schedule

1 Section V.1.

Deliverables Course Curriculum Electronic–

Offeror format

CS/CO 1

Copy

COR 1

Copy

NLT 30 days from contract award

2 Section V.1.

Deliverables Instructor Schedule Electronic–

Offeror format

CS/CO 1

Copy

COR 1

Copy

NLT 30-45

days from contract award

3 Section V.1.

Deliverables

Pre- and Post-Training Test Development

Electronic– Offeror format

CS/CO 1

Copy

COR 1

Copy

NLT 30-45

days from contract award

4 Section V.1.

Deliverables Write PowerPoints Electronic–

Offeror format

CS/CO 1

Copy

COR 1

Copy

NLT 30-45

days from contract award

5 Section V.1.

Deliverables

Write manuals, handouts, group and individual activities, and any other course materials, and print all documents for course

Electronic– Offeror format

CS/CO 1

Copy

COR 1

Copy

NLT 30-45

days from contract award

6 Section V.2.

Deliverables Action Report(s) Electronic–

Offeror format

COR 1

Copy

Each quarter covering the prior three months

7 Section V.2.

Deliverables Final Report Electronic–

Offeror format

COR 1

Copy

CS/CO 1

Copy

NLT 20 days following the completion of all training for the entire period of performance

CLIN

Deliverables Financial Forensic Accounting Training and Assistance

Quantity Unit

1 Project Management 4 LT 2 Curriculum Development 1 LT 3 Course Delivery 3 LT

4 Reporting Deliverables 4 LT

5 Other Direct Costs (ODCs) - Hotel. Travel, Per Diem, Local Transportation, training venue 1 LT

6 Administrative Expenses 1 LT

1. PRICE: The price shall include all direct and indirect costs, shipping, profit, export requirements, insurance, etc. The price will not be subject to adjustment after award of the contract.

2. RECEIVING: The vendor is required to replace any defective items at no additional cost to the Government.

3. WARRANTY:

The contractor shall provide all warranty information and service.

BASIS OF AWARD

EVALUATION OF QUOTATIONS:

• Award from this solicitation will be made on an “All or None” basis.

• Award will be made based on the Lowest Priced-Technically Acceptable (LPTA) quote that is responsive to the Request for Quote (RFQ) requirements

ADDITIONAL CONSIDERATIONS

1. The Government reserves the right to reject a quotation that is technically unacceptable or unreasonably high in price.

2. The Government will determine acceptability by assessing the quoter's compliance with the terms of the RFQ.

3. The quoter must be able to demonstrate that it has the necessary resources to provide on-time delivery as well as a high level of quality for the requested items.

2. RECEIVING: The vendor is required to replace any defective items at no additional cost to the Government.