Signed.V3 Sole Source Justification.pdf

SSJ (GSAR 538.71 & Part 8.4) Control No. XX-XX

Procurement Sensitive - See FAR 2.101 and 3.104 For Official Use Only

SOLE SOURCE JUSTIFICATION

FOR ORDERS PLACED OR BPAS ESTABLISHED AGAINST FSS CONTRACTS

UNDER GSAR 538.7104-3; FAR 8.401

This action is governed by Executive Order (E.O.) 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025, and the resulting regulatory changes implemented by the Federal Acquisition Regulatory Council;s model deviation text to Federal Acquisition Regulation (FAR) Part 8, specifically by FAR Class Deviation 25-20. The stated purpose of these updates is to empower acquisition professionals to use innovative approaches to acquire products/services/solutions under the Federal Supply Schedule (FSS) program. (Per GSAR 538.71; FAR 8.401).

1. Identification of the Agency, Contracting Activity, and Specific Identification of the Document.

(a) Agency: Drug Enforcement Administration

(b) Contracting Activity: DEA Office of Acquisition

(c) Requiring Activity: Office of Administration

(d) Document Identification: Sole Source Justification

2. Nature and Description of the Action Being Approved: The services required under this action are for the acquisition of a financial investigation solution and associated support services to enhance the Government’s ability to investigate illicit drug trafficking, money laundering, and other complex financial crimes. The Drug Enforcement Administration (DEA) requires a financial system capable of handling large volumes of financial records and transactional data by automating the extraction, verification, reconciliation, analysis, and visualization of financial information. This capability will enable investigators to identify financial relationships, trace the movement of illicit proceeds, and develop actionable financial intelligence in support of money laundering investigations. This action seeks approval to acquire these capabilities through Valid8 Financials’ financial investigation platform.

(a) Contractor Name: Valid8 Financial

(b) Type of Action: Purchase Order (c)

(d) No (double-click to check; under “Default value”

Estimated Amount:

Recurring Requirement: Yes choose “checked”)

(e) FSS Contract Number: N/A

(f) Period of Performance: From: 09/30/2026 To: 09/29/2027

(g) Description: Commercial-Off-the-Shelf (COTS) software licenses, maintenance, and support for Valid8 Financials’ investigation platform, which provides automated financial data extraction, reconciliation, analysis, and visualization capabilities.

Description of Supplies or Services: SOW is attached to support this request.

Identification of the Sole Source Consideration Rationale:

Exceeding MPT, but not exceeding the SAT. GSAR 538.7104-3(a) Exceeding MPT, but not

For Official Use Only exceeding the SAT. The ordering activity contracting officer must determine in writing that the circumstances of the acquisition deems only one source reasonably capable of providing the products, services, or solutions (e.g., urgency, exclusive licensing agreements, items particular to one manufacturer);

Exceeding the SAT. GSAR 538.704-3(b)(1) Statutory Exceptions. The statutory exceptions supporting the placement of an order or establishment of a FSS BPA that exceeds the SAT on a sole source basis are:

GSAR 538.704-3(b)(i) The need is of such unusual urgency that following the procedures would result in unacceptable delays in fulfilling that need;

GSAR 538.704-3(b)(ii) Only one source is capable of providing the products, services, or solution required at the level of quality required because the products, services, or solutions are unique or highly specialized;

GSAR 538.704-3(b)(iii) The order should be issued on a sole source basis in the interest of economy and efficiency because it is a logical follow-on to an FSS order already issued on a competitive basis;

GSAR 538.704-3(b)(iv) It is necessary to place the order with a particular FSS contractor to satisfy a minimum guarantee established in the FSS BPA; or

GSAR 538.704-3(b)(v) A law expressly authorizes or requires that the purchase be made from a specified source.

Items peculiar to one manufacturer GSAR 538.7104-4(b) The particular brand name, product, or feature is essential to the ordering activity’s requirements, and market research indicates other companies’ similar products, or products lacking the particular feature, do not meet, or cannot be modified to meet, the need.

5. Description of the Sole Source Rationale: Why is this the only source? (e.g., proprietary technology, compatibility, unique expertise). Explain the contractor’s unique qualifications and capabilities to support your requirement. Are there other like/similar products that meet this requirement and why you are precluding them for this acquisition?

Market research identified several commercially available products with capabilities that overlap portions of DEA’s requirement. Some solutions primarily provide financial document extraction and conversion of banking records into structured data, while others focus on accounting, fraud analysis, or general investigative support. Although these products provide useful individual capabilities, they do not provide the same integrated forensic workflow required to reconstruct complex financial activity and maintain traceability to the underlying source evidence.

Valid8 provides an integrated forensic financial investigation capability that processes and verifies source financial records, reconciles transactions, and reconstructs financial activity across multiple accounts and entities. A key capability is source-evidence traceability, which allows investigators to trace analytical findings and individual transactions back to the underlying financial records supporting those findings.

This enables investigators to not only determine how funds moved but also validate and substantiate their analysis using the original financial evidence – an important requirement in complex money laundering, illicit drug trafficking and other financial crime investigations.

For Official Use Only

While alternative products may satisfy individual components of the requirement, the Government’s market research did not identify another solution that provides the required combination of forensic financial reconstruction, flow-of-funds analysis, and source-evidence traceability within a single integrated platform. Replicating the required capability through multiple products would introduce additional manual processing and reconciliation and would require investigators to move between separate systems to reconstruct and substantiate financial activity. Based on the market research conducted, Valid8 is the only identified solution that satisfies the Government’s complete forensic financial investigation.

6. Contracting Officer’s Determination that the Order Represents the Best Value: Explain how this price is fair and reasonable (e.g., comparison to GSA schedule price, price analysis).

I hereby determine that:

The order represents the best value to DEA consistent with the requirements of FAR 8.401 and (price evaluation is attached); and, If a particular brand name, product feature is requested, I hereby determine that it is essential to the Government’s requirements, and as demonstrated by the attached market research, or other companies’ similar products, or products lacking the particular feature, do not meet, or cannot be modified to meet, the Department’s need.

I certify that the information contained in this justification is accurate and complete to the best of my knowledge and belief. In accordance with FAR 8.401, this certification serves as approval of this sole source justification for orders up to $900,000.00.

Signature Date

7. Market Research Description: (e.g., issuing a notice of intent to sole source on GSA e-Buy, reviewing data from previous acquisitions., reviewing published data from the web, and/or consulting with the acquisition team, knowledgeable acquisition, and program officials in government and industry regarding market capabilities).

8. Other Facts Supporting the Sole Sources Justification: Complex financial investigations involving money laundering and illicit drug trafficking often require investigators to review and reconstruct large volumes of financial records across multiple accounts, institutions, and entities. Manual review and reconciliation of these records is resource-intensive and can significantly increase the time required to identify and trace illicit proceeds.

Valid8 provides investigators with a consolidated forensic environment for processing financial evidence, reconstructing transaction activity, tracing the movement of funds, and validating analytical findings against original source documentation. Source -evidence traceability is particularly important because it allows investigators to substantiate identified transactions and financial relationships using the underlying records rather than relying solely on derived analytical data.

The use of an integrated solution reduces reliance on sperate tools and manual processes throughout the financial investigative workflow. This capability will allow investigative personnel to devote greater resources to analysis and investigative decision-making rather than data preparation and reconciliation, For Official Use Only while improving the consistency, reproducibility, and defensibility of financial analysis used to support complex criminal investigations.

Actions Taken to Remove Barriers to Competition: There are no A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made. Steps taken to allow for future competition. Planned actions to increase competition for future, follow-on requirements.

Program Office Official’s Certification: I certify that the information provided in this justification is complete and accurate to the best of my knowledge and belief.

Approvals: The required levels of approval of this Sole Source Justification depend on the estimated total value of the procurement. Approval must be obtained for that level and each previous level.

Contracting Officer (for actions )

Signature Date Bureau Competition Advocate (for actions )

Signature Date

Bureau Procurement Chief (for actions )

Signature Date

Head of the Contracting Agency of Designee (for actions )

Signature Date

Senior Procurement Executive (for actions )

Signature Date

SOMAIEYA

KHURRAM

Digitally signed by

SOMAIEYA KHURRAM

Date: 2026.09.17 15:26:16 -04'00'

DENISE SCOTT

Digitally signed by DENISE

SCOTT

Date: 2026.09.17 14:51:04 -05'00'