Limited-Sources Justification - Redacted.pdf

Treasury Standard Form – 1012 (Rev 5/18)

Prescribed by Treasury: DTAP 1008.405-6

DEPARTMENT OF THE TREASURY

LIMITED-SOURCES JUSTIFICATION

This acquisition is conducted under the authority of the Multiple Award Schedule Program (see FAR 8.401)

1. Identification of the agency and the contracting activity:

The requiring activity is the Department of the Treasury (Treasury) Office of Foreign Assets Control (OFAC) and the contracting activity is The Internal Revenue Service (IRS) Office of Procurement, Office of Business Solutions Acquisition, Treasury Operations Branch (TOB).

2.a Nature and/or description of the action being approved:

The purpose of this limited-sources justification is to obtain approval to award a firm-fixed-price task order with Dun & Bradstreet (D&B) against GS-00F-022DA for the purchase of the unique service described in section 3.a below. The need date for these items is October 1, 2020. The period of performance will be for one 12-month period from October 1, 2020 through September 30, 2021.

2.b Name of the vendor: Dun & Bradstreet 2.c Requisition No.: 21PR-TDP-0015 2.d Bridge contract: ☐ Yes ☒ No 2.e Brand name: ☒ Yes ☐ No 3.a A description of the supplies or services required to meet the agency’s needs:

The proposed acquisition is to acquire subscription services to the D&B Global Reference System (GRS) .

3.b Includes IT: ☐Yes ☒ No 3.c IGCE/Estimated dollar value:

4.a Identification of the authority being used (Check the appropriate box that applies).

□ FAR 8.405-6(a)(1)(i)(A) – An urgent and compelling need exists, and following the procedures would result in unacceptable delays.

☒ FAR 8.405-6(a)(1)(i)(B) – Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

□ FAR 8.405-6(a)(1)(i)(C) – In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order or BPA provided that the original order or BPA was placed in accordance with FSS procedures in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

☐ FAR 8.405-6(b) – Items peculiar to one manufacturer.

4.b Supporting Rationale:

The proposed Contractor's data is protected rights information and D&B does not allow access to its proprietary databases through third party resellers. This data incudes information consisting of an integration of intelligence feeds from commercial sources for both physical and cyber threats. Dun & Bradstreet’s unique database allows OFAC investigators to access information on more than 100 million businesses worldwide including 38 million in the United States. D&B is the leading provider of business information for credit, marketing, and purchasing decisions worldwide. The information D&B provides is gathered and compiled from millions of trade and bank transactions, federal bankruptcy filings, information from business owners, public utilities, and the offices of all the U.S. Secretaries of State. D&B also

DEPARTMENT OF THE TREASURY

LIMITED-SOURCES JUSTIFICATION

This acquisition is conducted under the authority of the Multiple Award Schedule Program (see FAR 8.401) scours information from hundreds of newspapers, magazines, trade publications, and electronic news services for data.

5. A determination by the ordering activity Contracting Officer that the order or BPA represents the best value consistent with FAR 8.404(d):

determined the fixed price for the user subscription described in block 3 under contract GS-00F-022DA is fair and reasonable. Additionally, it is determined that awarding a firm-fixed-price order against GSA GS-00F-022DA represents the best overall value to the government, and

6. A description of the market research conducted among schedule holders and the results or a statement why market research was not conducted:

A market survey was conducted previously for the current contract to include review of other publications in seeking competitive bids. Trade Journals and other databases have been analyzed over the last several years, however, these sources are not able to provide other vendors' proprietary data Rights information. Attempts have been made to secure full and open competition pursuant to similar requirements published within FedBizOpps. It has been demonstrated based on past and current experience in purchase of this subscription service that it is proprietary in nature and each source vendor has its unique compilation and dissemination practices. To meet the legal requirements of a financial sanctions action, OFAC is required to have multiple sources verifying critical information. OFAC has existing contracts with ACNET, BYINGTON, Thomson Reuters and others for similar information in order to meet this legal standard. In addition, each source has its own unique information and sources which add value to our final product.

7.a Any other facts supporting this justification:

OFAC’s sole source justification for using Dun & Bradstreet (D&B) is due to the unique research tool that D&B provides, which is essential in supporting the identification of information relevant to individuals, addresses, assets, and businesses that are directly related to OFAC’s Specially Designated Terrorist and Specially Designated Narcotics Trafficking listings. Although the information is similar to data from other companies, it does provide unique perspectives and some uniquely sourced information.

OFAC would be at a disadvantage if the Dun & Bradstreet contract were not renewed yearly because it would cause disruption to ongoing OFAC investigations and investigatory research in support of specific actions initiated by Treasury.

7.b Attachments: ☐Yes ☒ No

8. A statement of the actions, if any, the Requiring Activity and Contracting Activity may take to remove or overcome any barriers that led to restricted consideration before any subsequent acquisition for the supplies and services is made:

The Program Office and Contracting Officer will continue to conduct testing in the market for changes in products available from other companies and in the requirement, which might lead to evaluating and selection of multiple competitors for this requirement.

9. Certifications and Approvals:

9.a Program Office Certification (Requiring Activity). I hereby certify that any supporting information and data provided (e.g., the Government’s minimum needs or requirements, or other rationale for the limited sources) and which form the basis for this justification for an exception to fair opportunity, are accurate and complete to the best of my knowledge and belief.

Name: Date:

Signature:

9.b Contracting Officer Certification and Approval. I hereby determine the circumstances of this acquisition support the justification to acquire these supplies or services on a limited source basis. I also certify this limited-sources justification is accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as the authorized contracting officer for this acquisition, I hereby approve the processing of this requirement on a limited-source basis.

Name: Date: