FP - DFOP0018070 Q+A.docx

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Western Hemisphere Counterterrorism Legal and Financial Disruption Program
Opportunity number
DFOP0018070
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This file is a Questions and Answers document supporting the Western Hemisphere Counterterrorism Legal and Financial Disruption Program funding opportunity. The document provides clarifications on key program parameters, application requirements, and implementation expectations for prospective applicants seeking to deliver structured legal and financial-disruption training to investigators, prosecutors, and judges across Latin America and the Caribbean. The Q&A addresses inquiries related to eligible recipients, geographic focus areas, training curricula standards, coordination with existing regional initiatives such as the International Law Enforcement Academy (ILEA), performance metrics, and compliance with National Security Presidential Memorandum-2 (NSPM-2) regarding Iranian proxy threats.

The program operates under CFDA 19.701 (Global Counterterrorism Programs) administered by the Department of State Bureau of Counterterrorism, utilizing Cooperative Agreement funding instruments. Applicants are expected to demonstrate capacity for multi-agency coordination, develop practical training modules focused on terrorism case investigation and prosecution, support financial network disruption efforts targeting Foreign Terrorist Organizations, and facilitate information-sharing mechanisms with U.S. counterparts. The funding mechanism emphasizes sustainable capacity-building with train-the-trainer components and measurable performance outcomes across the Western Hemisphere region, with particular attention to newly designated FTOs in Latin America and the Caribbean.

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NOFO DFOP0018070 – Western Hemisphere Counterterrorism Legal and Financial Disruption Program

Application Questions:

1. Will DOS/CT allow 10-point Times New Roman font for tables, graphics, and footnotes?

Answer: Text in tables, graphics, and footnotes, can be 10-point Times New Roman. All other text must adhere to the 12-point Times New Roman guidance in the NOFO.

2. Could DOS/CT confirm that the Logic Model and preliminary PMP are attachments and not included in the 12-page limit for the narrative?

Answer: These are excluded from the 12-page limit.

3. A table of content and an acronyms list may be provided for ease of reference. Could DOS/CT confirm that the table of content and acronyms list are not included in the 12-page limit for the narrative?

Answer: Section D.3 notes that the 12-page limit does not include a title page, table of contents, attachments (listed in D.5) and mandatory application forms (listed in D.1). An acronym list would also not contribute to the page limit.

4. Could DOS/CT confirm that submission can be made via either grants.gov or MyGrants?

Answer: Section E.6 notes that all application materials must be submitted electronically through Grants.gov or MyGrants.

5. Could DOS/CT confirm whether a copy of the applicant’s most recent audit is required for submission?

Answer: Public international organizations (PIOs) are not required to submit an audit.

Applicants can request exemption if they have not been incorporated for more than a year at the time of applying.

A copy of the most recent audit is not required for submission at the time of application.

For non-PIOs, an audit report or other document to help assess the financial status of the organization may be requested in the event the organization is selected for an award.

Country Selection:

1. Is the program expected to work in a set list of countries, or can the implementer recommend certain countries to work in based on knowledge and operating capability?

Answer: The implementer may recommend countries based on knowledge and operating capability. The program should focus on countries with newly designated FTOs in Latin America and the Caribbean, as well as countries where Iranian proxy threats are present to support implementation of NSPM-2. The NOFO specifically mentions the Andean region—especially Bolivia, Brazil, Chile, Colombia, Ecuador, and Peru—as areas with porous borders exploited by FTOs, however the project is not limited to those countries. See question 8 under this section for a list of countries that should not be included at this time.

2. Could the Government provide additional guidance on priority countries or sub-regions within the Western Hemisphere for program implementation? If not predetermined, should offerors assume a region-wide scalable model responsive to evolving CT priorities?

Answer: Countries should be determined based on the following criteria: presence of newly designated FTOs in Latin America and the Caribbean (including Los Lobos, Los Choneros, Tren de Aragua, Sinaloa Cartel, and CJNG), and countries where Iranian proxy threats exist to support implementation of NSPM-2. Grantees should propose a scalable, region-wide model that can respond to evolving CT priorities, with particular attention to the Andean region and areas with vulnerable financial sectors. Additional information on countries is listed under questions 7 and 8 in this section.

3. Who generates the “demand signal” for such trainings? The US embassy? The Partner? CT Bureau?

Answer: The demand signal for country participation will be generated through coordination among DOS/CT Bureau, U.S. Embassies, and partner country governments. DOS/CT will maintain substantial involvement in selecting all beneficiaries and providing ongoing strategic guidance to ensure program activities align with U.S. foreign policy objectives and current intelligence and policy priorities. The grantee should propose a method for addressing ad hoc training requests/needs both bilaterally and regionally.

4. To what extent has this NOFO been discussed with national authorities within the region?

Answer: If selected, CT Bureau will provide information as to any ongoing discussions. However, applicants should propose how the program will engage or obtain support from relevant stakeholders, including host governments, to obtain access and conduct programming.

5. The NOFO mentions specific countries in the Andean region. Should the response focus on particular countries or specific FTO entities, or is it more desirable that the response present an intervention that can be used throughout Latin America and the Caribbean at the discretion of DoS CT Bureau?

Answer: The response should present a flexible, region-wide intervention that can be used throughout Latin America and the Caribbean at the discretion of DOS/CT Bureau. While the NOFO highlights the Andean region and specific FTOs, it calls for a program that can address both newly designated FTOs regionally and Iranian proxy threats, with DOS/CT maintaining substantial involvement in advising on priority countries, regions, and threat actors based on current intelligence and policy priorities.

6. Is there a preference for countries in which to hold the regional workshops mentioned in the NOFO?

Answer: Applicants should propose appropriate locations for regional workshops and training activities, considering factors such as accessibility, security, and relevance to program outcomes. Partnerships with local institutions such as law schools or public entities responsible for addressing terrorism are encouraged. If selected, CT Bureau will provide information as to any ongoing discussions and policy priorities for workshop locations.

7. Which specific countries, provinces, and/or regions/sub-regions are considered priority areas for program activities?

Answer: Priority areas include countries with newly designated FTOs in Latin America and the Caribbean, with particular emphasis on the Andean region (Bolivia, Brazil, Chile, Colombia, Ecuador, and Peru) where porous borders are exploited by terrorist and transnational criminal organizations. The program must also address Iranian proxy threats throughout the hemisphere to support NSPM-2 implementation.

8. Are there any locations that should be excluded for income threshold or other reasons?

Answer: At this time the project should not include the following countries: Cuba, Haiti, and Nicaragua, and Venezuela.

ILEA Deconfliction:

1. Will DOS support coordination between the ILEAs and the implementing partner for this program?

Answer: DOS/CT will provide connections to the regional ILEA. Potential implementers should identify any other relevant initiatives.

2. Will DoS CT Bureau provide the necessary liaison/connections with the International Law Enforcement Academy (ILEA) so that the implemented might ensure deconfliction?

Answer: DOS/CT will provide connections to the regional ILEA. Potential implementers should identify any other relevant initiatives.

Project Questions:

1. Can the Government provide estimated annual targets for the number of participants, partner countries, or engagements expected under this program to inform program design and resource planning?

Answer: The NOFO does not specify predetermined targets. Applicants should propose realistic targets for participants, partner countries, and engagements as part of their Performance Monitoring Plan (PMP), including at least three relevant CT-wide Indicators (from final page of the provided CT PMP Template/How-To Guide), with established baselines and targets for each performance indicator. Proposed targets should align with the program's 24-month performance period and available funding of up to $8,880,118. Priority is effectiveness of meeting program outcomes and not quantity of participants.

2. To what extent does the Government envision direct advisory support to partner governments on legislative and regulatory reform (e.g., drafting laws, advising ministries), versus training and capacity building for implementation of existing frameworks?

Answer: The program should include both elements. The NOFO calls for technical assistance and guidance to countries interested in pursuing terrorist designations and sanctions, as well as support for the development, enhancement, and implementation of terrorist designation and sanctions regimes, including legislative and regulatory assistance. Additionally, the program should deliver formal, practice-oriented training to investigators, prosecutors, and judges on disrupting and dismantling FTO networks.

3. What level of engagement with private sector actors (e.g., financial institutions, MSBs) does the Government anticipate (e.g., awareness training vs. operational integration with national authorities)?

Answer: The focus should primarily be on civilian law enforcement/ the criminal justice sector; however, the program can also include a focus on high-risk financial sectors vulnerable to money laundering and terrorist financing, including money service businesses (MSBs), remittance locations, free trade zones, ports, and logistics hubs. CT Outcome 4 specifically calls for strengthening private sector understanding of identified risks and taking appropriate mitigation measures, including increased reporting of suspicious transactions to national authorities. Both awareness training and operational integration are encouraged.

4. The NOFO references the ability to respond to ad hoc training requests. Should offerors assume a standing surge capacity, and if so, are there expectations regarding response timelines or reserved level of effort?

Answer: Yes, offerors should propose a method for addressing ad hoc training requests/needs both bilaterally and regionally. The NOFO does not specify response timelines or reserved level of effort, but applicants should include a contingency plan to account for delays in implementation and other timeline issues. Given DOS/CT's substantial involvement in program implementation, flexibility and responsiveness to evolving threats and policy priorities are essential.

5. The NOFO mentions working with investigators, judges, and prosecutors. Will DoS CT Bureau facilitate these connections, or is the implementer expected to have these in place already? If so, which countries should the focus be?

Answer: DOS/CT will maintain substantial involvement in the selection of all beneficiaries. However, applicants should demonstrate an institutional record of previous successfully implemented programs in the regions outlined in the NOFO and articulate past performance and experience in working with relevant host governments, local organizations, and communities. The focus should be on countries with newly designated FTOs in Latin America and the Caribbean, particularly the Andean region, and countries where Iranian proxy threats exist.

6. Is hardware/software procurement anticipated? Are there restrictions on categories of support provided through the program?

Answer: Hardware/software procurement is allowable but not explicitly anticipated as a primary program component. The NOFO focuses on training, and technical assistance for investigators, prosecutors, and judges. If hardware/software is necessary to support program outcomes, it may be included in the budget. Equipment (items with a useful life of more than one year costing at least $10,000 per unit) and supplies (including computer devices costing less than $10,000 per unit) are both allowable budget categories. All proposed costs must be reasonable, necessary, and linked to CT program outcomes.

7. Should the four DOS/CT Program Outcomes be treated as the program’s primary objectives?

Answer: Yes, the outcomes should be treated as the program’s primary objectives.

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