Justification Approval Form Other than Full and Open Competition Redacted.pdf

FEDERAL BUREAU OF INVESTIGATION

FINANCE AND FACILITIES DIVISION | PROCUREMENT SECTION

JUSTIFICATION AND APPROVAL (J&A) FOR OTHER THAN

FULL AND OPEN COMPETITION

SHOP-PR-26-0001645 Procurement Section Format Update: 06/22/2026

Justification for Other than Full and Open Competition in Accordance With 41 U.S.C. 3304 (A) (1)

Requisition Number: SHOP-PR-26-001645

Title: CED Capital IQ Financial Data Date: 8/28/2026 Estimated Contract Dollar Value: $3,591,617.59

1. Identification of the agency and the contracting activity.

The U.S. Department of Justice, Federal Bureau of Investigation (FBI), Professional Services Acquisition Unit, has prepared this Justification for Other than Full and Open Competition for Financial Data Support Services on behalf of the Counterintelligence and Espionage Division (CED) and Security Division (SecD).

2. The nature and/or description of the action being approved, i.e. sole source, limited competition, establishment of a new source, etc.

In accordance with a statutory exception to the fair opportunity process, the FBI is requesting approval to acquire a brand-name subscription to the Capital IQ database. This brand-name requirement is necessary because research confirmed that while some platforms offer partial financial data, none provide the same integrated datasets, proprietary screening functions, industry-specific analytics, or advanced transaction research capabilities required by the FBI’s Counterintelligence & Espionage Division, Foreign Investment Unit, and Acquisition Security Unit.

Additionally, the FBI is requesting a sole source award to S&P Global Market Intelligence because the Capital IQ data licenses and API access are sold only through S&P Global Market Intelligence. The contractor does not authorize resellers, distributors, or third parties to license or deliver this product.

As a result, no other sources are capable of meeting the agency’s requirements, necessitating a brand-name, sole source acquisition.

3. A description of the supplies or services required to meet the agency’s needs (including the estimated value)

The FBI, Counterintelligence & Espionage Division (CD) and Security Division (SecD), requires access to Capital IQ data licenses, which includes information on over 4.4 million companies and over 2.9m professionals across the globe. These licenses offer current financial intelligence on public companies and enable users to parse relevant financial data for research and analysis. Capabilities include competitor and market analysis, corporate actions and events, transactions, screening and charting, and alerts. The contractor will provide access through an UNCLASSIFIED computer network to their proprietary database of industry/sector data.

The FBI’s Foreign Investment Unit (FIU) and Acquisition Security Unit (ASU) require unlimited access to a commercial financial database that provides company screening capabilities, downloadable financial transaction data, market research, and industry and sector specific financial data in order to conduct company and person research on potential internal FBI acquisitions; analytical research in support of the Committee on Foreign Investment in the United States (CFIUS) and Team Telecom transactions; and targeting and exploitation of transactions in order to support the identification of non-notified CFIUS transactions. Access must include an Application Programming Interface (API) feed that provides business relationships, base company information, detailed transaction data, and cross reference services.

4. The statutory authority permitting other than full and open competition.

The statutory authority permitting other than full and open competition is 41 U.S.C. 3304 (a)(1) as implemented by the Federal Acquisition Regulation (FAR) Subpart 6.103-1 entitled, “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.” The content of these Services is the sole and exclusive property of S&P Global.

5. Demonstrate that the proposed contractor’s unique qualifications or the nature of the acquisition requires using the authority cited.

S&P Global is uniquely qualified to provide these services to the FBI. Capital IQ is a proprietary platform, and all data, analytical tools, screening functions, and API features are the exclusive property of S&P Global Market Intelligence LLC, its affiliates, and licensed data providers. No other commercial vendor produces, distributes, or maintains the Capital IQ platform, and the product is not available through resellers or third-party distributors. While certain general financial data may be available from other sources, the specific Capital IQ dataset, its integrated structure, and its unique analytical capabilities are only obtainable through direct licensing agreements with S&P Global Market Intelligence. For these reasons, the FBI’s requirement is both brand-name and available solely from one responsible source.

6. A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will not be publicized as required by Subpart 5.1 and, if not, which exception under 5.101 applies.

Market research was conducted to determine whether any alternative products or vendors could meet the FBI’s requirement for the brand-name Capital IQ financial database. The FBI reviewed other commercial financial data platforms, including

, to assess whether their datasets, analytical tools, transaction-level financial intelligence, and

API capabilities were comparable to Capital IQ. Research confirmed that while some platforms offer partial financial data, none provide the same integrated datasets, proprietary screening functions, industry-specific analytics, or advanced transaction research capabilities required by the FBI’s

Counterintelligence & Espionage Division, Foreign Investment Unit, and Acquisition Security Unit.

As part of market outreach, the FBI contacted S&P Global Market Intelligence to verify distribution channels and confirmed that the Capital IQ platform is sold exclusively by S&P Global Market

Intelligence and is not available through resellers or third-party vendors. Industry research, vendor capability reviews, and product comparisons collectively identified no alternative sources capable of providing the required brand-name product.

In accordance with FAR Subpart 5.1, the FBI will publicize the proposed sole-source acquisition on SAM.gov. This ensures maximum practicable notice, even though market research confirms that only one responsible source exists.

The estimated cost for this task is $3,591,617.59. The estimated Period of Performance (POP) for this new contract is one (1) base year plus four (4) option years as follows:

Period Begin End

Base Year 9/30/2026 9/29/2027

Option Year 1 9/30/2027 9/29/2028

Option Year 2 9/30/2028 9/29/2029

Option Year 3 9/30/2029 9/29/2030

Option Year 4 9/30/2030 9/29/2031

52.217-8 Option to Extend

Services

9/30/2031 3/29/2032

7. A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The contract will be for one year with four option years and include a 6-month extension in accordance with FAR 52.217-8. The total estimated value is $3,591,617.59.

The contractor’s proposal will be subjected to cost/price analyses and technical evaluation. The Contracting Officer will determine, in accordance with FAR 15.404-1, that costs are fair and reasonable.

8. A description of the market research conducted and the results.

Market research included reviewing mandatory sources, such as Ability One. This research did not result in finding a compatible service type on the Ability One service type procurement list search engine.

The FBI’s FY26 BPA and IDIQ List was reviewed and was unsuccessful in finding a compatible internal vehicle. The Contracting Officer Representative participated in interactive, on-line communication among industry, acquisition personnel, and customers, obtained source lists of similar items from other contracting activities or agencies, trade associations or other sources, reviewed catalogs and other generally available product literature published by manufacturers, distributors, and dealers or available on-line, conducted interchange meetings or holding pre-solicitation conferences to involve potential offerors early in the acquisition process, and reviewed systems such as the System for Award Management, the Federal Procurement Data System, and the Small Business Administration's Dynamic Small Business Search. Multiple contracts from other agencies were reviewed and no contracts with other Government agencies can be used to place orders on. Through this search, multiple contracts from other agencies involved sole sourcing to S&P Global. Upon review, the FBI became aware that the Capital IQ license may be proprietary to S&P Global. The Contracting Officer requested a letter from S&P Global detailing why the services/licenses are proprietary. S&P Global returned a signed letter on company letterhead that explained that the services/licenses to be procured are the sole and exclusive property of S&P Global. While services may be obtained through other sources, to obtain access to these services, the FBI must enter into agreement with S&P Global.

9. Any other facts supporting the use of other than full and open competition.

The Capital IQ license includes information on over 4.4 million companies and over 2.9m professionals across the globe. Additional information includes competitor and market analysis, corporate actions and events, transactions, screening and charting, and alerts. Capital IQ's extensive data set serves as a key component to how the FBI screens foreign transactions for national security purposes. This ability to screen transactions allows for the creation of custom filtered sets of data, reports and charts that no other database compares too. For example, the data that is provided by Capital IQ directly feeds into a proprietary FBI database that is used to score, rank, and analyze foreign transactions that are utilized in FBI investigations, intelligence analysis, and targeting purposes. FIU relies on Capital IQ data to run its triage tool which provides rank scoring of transactions that may affect national security. If the FBI no longer had access to this data, there would be a severe impact on mission and an increased labor and data cost to appropriately pivot with a new subscription.

The PitchBook license provides insight into over 5 million companies, service providers, limited partners, and people and specifically includes information on private equity funds, hedge funds, and venture Capital fund investments. PitchBook is user-friendly providing keys pieces of company, transaction, and background information that sometimes is not found in Capital IQ. Additionally, PitchBook provides more information within the venture capital space that is important when looking into start-up companies and their initial investors. However, PitchBook does not provide granular – deal specific information that would need to be ingested into the FIU triage tool. PitchBook also does not have the ability to screen transactions.

The Eikon license is a premiere business news data source that provides real-time financial news, company’ data such as profiles, financial information, breaking news, and transaction information. Eikon provides the capability to do deep dives into a specific country such as larger economic and financial data (GDP, regulatory information, bonds, equities, etc.) as well as a trove of financial data and information.

However, Eikon’s data platform is not as user friendly as Capital IQ or PitchBook nor does it provide granular – deal specific information that would need to be ingested into the FIU triage tool. This also includes the inability to screen transactions.

The FBI requires access to S&P Global’s sole and exclusive property to provide unlimited downloads and access to the data; not internally track, exploit or disclose the use of FBI searches; limited platform downtime for the FBI to access and use the information outside traditional work hours.

10. A listing of any sources, if any, that expressed a written interest in the acquisition.

A synopsis and notice of intent to sole source will be posted in accordance with FAR 5.101 on SAM.gov.

No vendors submitted written interest in response to the FBI’s market outreach or research efforts. During market research, the FBI contacted S&P Global Market Intelligence to verify whether any resellers, distributors, or third-party vendors were authorized to provide access to the Capital IQ platform. S&P Global confirmed in writing that it is the sole source and exclusive provider of all Capital IQ licenses and related data services. No other vendors expressed interest or asserted an ability to meet the FBI’s requirements, and no alternative sources identified themselves as capable of providing the brand-name items and proprietary data necessary for this acquisition.

11. A statement of any actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required.

The FBI will continue to monitor the financial data services market to identify emerging products, vendors, or technologies that may offer comparable capabilities to the Capital IQ platform. Prior to any future acquisition, the FBI will review available commercial solutions, reassess mission needs, and evaluate whether alternative datasets or tools could meet operational requirements. The FBI will also continue to conduct annual market research, engage with industry, review updates in financial intelligence platforms, and analyze new entrants to the market. If competitive alternatives become available that can meet the FBI’s technical, analytical, and API-level data requirements, the FBI will consider transitioning to a competitive procurement strategy. These steps will help ensure barriers to competition are minimized and future acquisitions are conducted using full and open competition whenever practicable.