Summary of Justification for Other Than Full and Open Competition

This is a Justification and Approval (J&A) document for a non-competitive contract award by the U.S. Department of State's International Narcotics and Law Enforcement (INL) Bogota office.

The contracting activity seeks to award a Firm-Fixed-Price (FFP) contract to TRM Labs on a sole-source basis for blockchain analytics software and related services to support Colombian law enforcement's anti-money laundering (AML) and counterterrorism financing investigations. The required deliverables include 26 TRM Forensics-Premium LE licenses (one user per license, one-year term) with virtual onboarding; 200 hours of dedicated professional services for complex investigation support over one year; 26 TRM Crypto Fundamentals Certifications (online, on-demand, in Spanish); 26 TRM Certified Investigator certifications (in-person, Spanish); 26 TRM Advanced Crypto Investigator certifications (in-person, Spanish); and 26 TRM Digital Forensics Specialist/Crypto Seizure Specialist certifications (in-person, Spanish). The estimated total value for the base period plus two option years is redacted, with an annual cost also redacted. The statutory authority for this non-competitive procurement is 41 U.S. Code 1901 as implemented by FAR 12.000.

The justification establishes that TRM Labs is the only vendor capable of meeting the Colombian National Police's (CNP) technical requirements due to its proprietary blockchain clustering technology, exclusive data sets, and heuristics that enable identification of masked IP locations, pattern-of-life analysis, and automatic detection of "tumbler" transactions. The contracting officer determined the anticipated price is fair and reasonable based on comparison with substantially similar commercial items, established commercial price lists, and prior federal agency negotiations for comparable TRM Labs licenses. Market research confirmed no other provider offers the combination of technical features, proprietary data, and compatibility with U.S. law enforcement systems. Other U.S. federal agencies and Colombian law enforcement partners already utilize TRM Labs, supporting information sharing and joint operations on transnational cases.