SSN_25TAF_SOSFFP_PWS_v1_Clean.pdf

Performance Work Statement

Strategic and Operational Support of Forfeiture Fund Programs

United States Department of Treasury

Treasury Executive Office for Asset Forfeiture

Treasury Forfeiture Fund DRAFT

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DRAFT

LIST OF ACRONYMS

3PML Third-Party Money Laundering AFTRAK Asset Forfeiture Tracking and Retrieval System AIC Office of Accounting and Internal Control ARC Administrative Resource Center BSA Bank Secrecy Act BMPE Black Market Peso Exchange BPA Blanket Purchase Agreement CBP Customs and Border Protection CO Contracting Officer COB Close of Business CONUS Continental United States COR Contracting Officer’s Representative CSF Contractor Storage Facilities DHS Department of Homeland Security DO Departmental Offices FASTRAK Forfeited Asset and Seized Property Tracking System FAR Federal Acquisition Regulation FP&F Fines, Penalties and Forfeitures

FTR

FY

Federal Travel Regulation Fiscal Year

GFE Government Furnished Equipment GFP Government Furnished Property GP General Property HSI Homeland Security Investigations ICE Immigration and Customs Enforcement IRS-CI Internal Revenue Service – Criminal Investigation JOAS Joint Operations Automated System MSB Money Service Business NFC National Finance Center OCONUS Outside Continental United States OIG Office of Inspector General PAR Performance Accountability Report RP Real Property SAP TEOAF’s Financial System that is owned and managed by CBP SEACATS Seized Asset and Cast Tracking System TBML Trade Based Money Laundering TEOAF Treasury Executive Office for Asset Forfeiture TFF Treasury Forfeiture Fund TTB Trade and Tax Bureau USCG United States Coast Guard USSS United States Secret Service

DEFINITIONS

3PML – Third-Party Money Laundering is one of the most important elements to successfully targeting major drug-trafficking organizations (DTOs) or transnational criminal organizations (TCOs) is the dismantling of the financial infrastructure that supports their operations. Accomplishing this goal requires dedicated effort focused specifically on targeting professional money laundering networks. These are very complex, long-term investigations that require resources, including extensive analytical support.

3PML investigations also rely upon analysis of large volumes of financial and trade records, rather than traditional investigative methods.

ADVERSE INCIDENT – Loss, damage, or destruction of GP, or GFP in the Contractor's custody. The GP Contractor has the following reporting requirements for Adverse Incidents:

a) The GP Contractor provides a quarterly Adverse Incidents Report to the CO and COR documenting any Adverse Incident that occurred over the previous quarter, and the open or closed status of all related issues, via electronic means. The Adverse Incidents Quarterly Report is submitted electronically by the tenth business day of the month following the end of the quarter. The report includes a description of any adverse incident and sets forth the property involved, the property’s Appraised Property Value and Fair Market Value, date of loss or damage, location of the incident, date and time of the incident, probable cause of the incident, names of any witnesses, the GP Contractor’s estimated value of the loss, a summary of the results of the Contractor’s investigation into the incident, any amount collected from subcontractors or vendors found at fault, and any reimbursements from the prime Contractor to the Government.

b) The GP Contractor provides an Adverse Incident Flash Report to the CO and COR with the details of an adverse incident and extent of any loss, destruction, or damage of property or unauthorized entry, regardless of value, no later than the COB the following business day after the Contractor is notified or has knowledge of such adverse incident.

c) The GP Contractor provides an Adverse Incident Final Report of investigation for each adverse incident to the responsible CBP FP&F Officer, or other seizing agency operational point-of-contact within 30 business days of the incident. The GP Contractor forwards the report to the CO and GP COR when the value of the loss, destruction, or damage exceeds $5,000. If a final report of investigation cannot be completed within 30 business days, an interim report is submitted in place of the final report, to include an explanation as to why the final report of the investigation could not be completed within the required 30 business day time frame.

AFTRAK – An information system developed to track asset seizure and forfeiture activity in conjunction with criminal investigations, and manage asset inventories and distribution of proceeds under the guidance of TEOAF.

BMPE – Evolved because of the Colombian Government banning US Dollars (USD) in the Colombian economy during the 1960’s to boost their currency and economic standing in the marketplace. Drug dealers supply bulk cash in America to an associate of a peso broker, and receive pesos in Colombia (or Mexico) in exchange. Legitimate importers in South America purchase dollars from the broker on the black market, as opposed to an official bank to pay for American goods to avoid high tariffs.

FASTRAK – An information system for tracking and reporting seized property and asset forfeiture inventory for the Secret Service.

FINANCIAL INSTITUTION CAPTURE – Money launderers buy a controlling interest in a small, private bank, and move money through it without scrutiny.

GP COR – Individual designated to support the GP Contract and is responsible for technical monitoring, inspection, approval of testing, and other functions of a technical nature.

JOAS - The Automated System for Joint Operations Payments is a web-based application hosted on the Treasury network. This system has been specifically designed to facilitate the processing of obligations and invoices related to the TFF participating agencies’ joint operations, and assist the agencies in managing joint operations funds. The system is accessible for Treasury and DHS.

LOCAL TRAVEL – Any travel within a 50-mile radius of the TEOAF headquarters.

MAJOR CASE – Any forfeiture investigation that will result in seizure and forfeiture of more than $1 Million, i.e. 3PML.

MSB - Used for the movement of criminal funds. There is a pressing need to enhance both regulatory and law enforcement efforts targeting unlicensed MSBs, as well as licensed MSBs abused by criminal organizations, particularly along the Southwest Border. The future effectiveness of these efforts is based not only on the existence of dedicated task forces and groups focused on MSBs, but also on comprehensive analytical support and tools to enable investigators to sort out large volumes of MSB transactional and BSA data.

NATIONAL FINANCE CENTER – They are a group within CBP and are the financial executors of the TFF. They are responsible for issuing all payments approved by TEOAF, and maintaining TEOAF’s financial statements and records.

ROLL FORWARD – TEOAF’s annual accounting records show all currency and property that is on hand with the government or with one of their property contractors. It is broken out by TFF participating agency and details the status of each property at the time of the fiscal year-end rolling forward to the beginning of the next fiscal year. It contains multiple exhibits relating to specific types of property and their status.

ROLL FORWARD EXHIBIT 5 – Roll Forward exhibit displaying all seized real property on hand with TEOAF TFF participating agencies or being held with one of TEOAF’s property contractors.

RP COR – Individual designated to support the RP Contract and is responsible for technical monitoring, inspection, approval of testing, and other functions of a technical nature.

SEACATS - The single repository for all inventory and case information related to seized and forfeited property, fines, penalties, and liquidated damages for CBP.

SHELL COMPANY OR TRUST - can help to further obfuscate the owner of money since in some jurisdictions there is no requirement to disclose the owner of a shell company or trust. A foreign-held trust is a common layering maneuver for intelligent money launderers, since trusts are very difficult to forfeit, due to issues of beneficial ownership.

TBML - The process of disguising the proceeds of crime and moving value using trade transactions to legitimize their illegal origins or finance their activities.

VIRTUAL CURRENCY - A medium of exchange that operates like a currency in some environments, but does not have all the attributes of real currency. Virtual currency does not have legal tender status in any jurisdiction. This guidance addresses "convertible" virtual currency. This type of virtual currency either has an equivalent value in real currency, or acts as a substitute for real currency.

SECTION C—DESCRIPTIONS/SPECIFICATIONS/STATEMENT OF WORK

C.1 BACKGROUND

The mission of TFF is to affirmatively influence the consistent and strategic use of asset forfeiture by participating agencies to disrupt and dismantle criminal enterprises. The TFF is administered by TEOAF.

The continued high-impact performance of the TFF reflects the ongoing hard work of the TFF’s law enforcement bureaus as well as the TFF management’s emphasis on major case initiatives, asset forfeiture program training, and a focused approach regarding a performance measure that gauges revenue from high-impact cases. It is TEOAF’s view that the greatest damage to criminal enterprise can be achieved through large forfeitures; hence it has set a target level of seventy-five (75) percent of its forfeitures to be high impact forfeitures.

The TFF was established in 1992 as the successor to what was then the Customs Forfeiture Fund. The TFF continues, in its capacity as a successful multi-departmental fund, representing the interests of law enforcement components of the Department of the Treasury (Treasury) and DHS. It is the receipt account for the deposit of non-tax forfeitures made by various TFF participating agencies, including, but not limited to:

• Treasury o IRS-CI o TTB

• DHS

o ICE - HSI o CBP o USSS o USCG

The creation of the TFF brought together all then-Treasury law enforcement agencies. Although some bureaus were subsequently transferred to DHS by the Homeland Security Act of 2002 (Public Law No.

107-296), they remain participants of the TFF. (See https://www.treasury.gov/about/organizational-structure/offices/Pages/The-Executive-Office-for-Asset-Forfeiture.aspx)

Effective law enforcement actions against criminal enterprises, from drug cartels to terrorist organizations, require depriving them of enabling assets and profits that support or stem from their existence. The TFF is derived from the forfeited assets of criminal enterprises. The TFF is a “special receipt account” (i.e., a resource account that provides funding to the participating law enforcement agencies to enhance their capabilities to conduct successful investigations and forfeitures).

DRAFT

https://www.treasury.gov/about/organizational-structure/offices/Pages/The-Executive-Office-for-Asset-Forfeiture.aspx https://www.treasury.gov/about/organizational-structure/offices/Pages/The-Executive-Office-for-Asset-Forfeiture.aspx

TEOAF, through the provision of leadership, guidance, and stewardship, works to maximize the impact of forfeitures performed by the participating agencies. As the administrator of the TFF, TEOAF performs the following functions:

• Promotes the use of proceeds from asset forfeitures to fund programs and activities aimed at disruption and dismantling criminal infrastructures, major case initiatives and activities enhancing forfeiture capabilities;

• Manages TFF revenues to cover the costs of seizure and forfeiture;

• Trains law enforcement personnel of the participating agencies in various aspects of asset forfeiture;

• Promotes cooperation among federal, state, and local law enforcement agencies through funding of expenses including equitable sharing, as well as the development of task forces;

• Promotes financial stability and vitality of the TFF;

• Coordinates TFF policy among the participating agencies through the precepts of risk management and identifies and initiates action to address program risks;

• Designates CORs for this and similar contracts relating to seized General Property and provide assessment on the Contractor’s risk management plans, procedures, and investigations on behalf of the TFF.

The TFF program is supported by a financial management team, strategic planning team, and two (2) property management contracts as follows:

Financial Management and Operations Section – is responsible for all aspects of budget formulation and execution including coordinating and responding to all inquiries from the Department, Office of Management and Budget, and Congress, funding allocation, refund and payment approval, performance management, program compliance and audit oversight..

Strategic Planning and Analysis Section – supports numerous facets of the TEOAF program such as analysis and monitoring of TFF participating agencies’ major cases/forfeitures (including 3PML investigations); development and oversight of TEOAF and its TFF agencies’ financial plans; development of training and outreach program; and automation of TEOAF’s internal processes.

GP Contract – provides property management and disposition services to support (a) the seizure and forfeiture program for TEOAF and (b) blocked general property of the Treasury, Office of Foreign Assets Control (OFAC). GP supports Treasury Departmental Office (DO) and the components within Department of the Homeland Security (DHS) that participate in the TFF by providing services for the receipt, possession, custody, management, and disposition of seized, blocked, or forfeited personal property of OFAC, TEOAF, and all governmental entities that participate in the TFF.

RP Contract – provides services for the receipt, possession, custody, management and disposition of seized, blocked, or forfeited Residential and commercial real estate property, operating businesses, and vacant land (real property) on behalf of TEOAF, the agencies participating in TFF, or OFAC when the seizing or blocking agency determines that contractor services for such property will be in the agency's best interest. RP supports the law enforcement operations of the affected agencies.

C.2 SCOPE OF WORK

The Contractor shall support TEOAF’s mission, to include TFF participating agencies, and to assist with maintaining robust TFF operations, which shall be compliant with the laws and regulations governing the TFF and Treasury programs. The Contractor must have expertise in program reviews, strategic analysis, process reviews, invoice reviews, analysis of financial information, and the documentation of financial transaction and programmatic processes. The Contractor must also have a strong understanding of the TFF operations, including but not exclusive to strategic planning, equitable sharing, refunds/remittances/mitigations, general and real property contracts, and components of major financial investigations. Additionally, the Contractor shall be proficient in detecting and providing suggested solutions for any deficiencies and/or any potential material weaknesses. Potential external sources for identifying areas of improvements or weaknesses are the Treasury Inspector General or TEOAF’s Independent Private Auditor. The Contractor shall provide services as described herein.

C.3 PERFORMANCE REQUIREMENTS

The Contractor shall provide financial, strategic, analytical, investigative, and operational support to TEOAF and its TFF Programs. The Contractor shall provide technical assistance to the TEOAF program, which is responsible for regulatory oversight of TFF programs; financial analysis; strategic development;

and reviews of documents and operations when requested in the following TFF program areas: Financial Management, Strategic Planning and Analysis, and General Property and Real Property Contracts.

C.3.1 TASK 1: FINANCIAL MANAGEMENT AND OPERATIONS SUPPORT

Provide technical assistance to the Financial Management and Operations Section as follows:

Task 1.A Compliance Review of Equitable Sharing Program (FFP)

1.A.1 - Provide technical assistance and perform compliance reviews on Equitable Sharing payments made to State and Local Agencies by the TFF. This task may require travel where the Contractor shall perform a review and reconciliation of the State and Local equitable sharing program. This task will include opening letters, closing letters, and final compliance reviews for State and Local Agencies1. The Contractor shall ensure that the State and Local records are in proper order and with no discrepancies with TEOAF’s records.

1.A.2 – Contractor shall provide a quarterly report of all open Equitable Sharing Compliance Reviews to the COR for approval that shall include:

a) Year

b) Agency

c) Contractor responsible for review

d) Status of State and Local Compliance

e) Required/Pending Actions

1 Examples can be provided by the COR

Task 1.B Obligation Reconciliation of Equitable Sharing and Refund Payments (FFP)

1.B.1 - Perform reconciliation, compliance reviews and analysis for Refund Payments made by TEOAF on behalf of ICE, HSI, IRS-CI, CBP and USSS. The Contractor shall provide the analysis to the COR for review and approval.

1.B.2 – Contractor shall provide a quarterly report to the COR for approval that shall include:

a) Summary of the task;

b) Explanation of the review process;

c) Identification of any issues; and

d) Conclusions to TEOAF Management.

Task 1.C Year-End Expenditure and De-obligation Review for TFF Agencies (FFP)

1.C.1 – Contractor shall review all TFF participating agencies’ prior fiscal year obligations, reimbursable submissions and expenditures to ensure the funds were used for the intended purposes and in accordance with the approved financial plans.

1.C.1.1 - TFF participating agencies receive annually approved financial plans and are allotted money periodically throughout the FY to fund those plans. In some categories, agencies expend their own funds first and seek reimbursement from TEOAF after services have been performed and/or items purchased.

1.C.2 – Contractor shall provide comprehensive compliance analysis including examining supporting documentation for obligations and expenditures for all TFF participating agency. Provide a report annually at the conclusion of each review to the COR for review and approval that shall include:

a) Summary of the task;

b) Explanation of the review process;

c) Identification of any finding or issues; and

Task 1.D Technical Assistance for Package Review for Equitable Sharing, Refunds, and Joint Operations Reimbursement (LH)

1.D.1 - Contractor will provide assistance with the evaluation of packages, receive from FM AD/Team Leads. To perform this task the contractor shall:

1.D.1.1- Review supporting docs required in the package as to completeness and accuracy. Documentation will include those required by TEOAF policies and procedures. Documents will be reviewed will be reviewed for completeness and mathematical accuracy.

1.D.1.2 - Provide findings, if any, and recommendations to the respective TEOAF Team Lead for the action accordingly. If case of non-compliance is detected (e.g. ineligible cases, undocumented, unapproved, or other deficiencies), the contractor shall return to the respective TEOAF Team Lead along with the recommendations.

1.D.1.3 - For packages resubmitted, because of non-compliance described in the previous step, the contractor shall review the case of non-compliance to ensure corrective action was taken. This process will continue until no more deficiencies are noted.

1.D.2 - Contractor shall provide technical assistance in other amin issues of the FM program as requested by TEOAF Management or CORs.

1.D.3 - Contractor shall provide a Quarterly report to the COR for approval hat

1.D.3.1 - Summary of Technical Assistance provided; and Identification of any open admin issues remaining at the end of the quarter.

C.3.2 TASK 2: STRATEGIC PLANNING AND ANALYSIS SUPPORT

Provide technical assistance to the Strategic Planning and Analysis Section as follows:

Task 2.A TEOAF Program Reviews (FFP)

2.A.1 - As directed by the COR, the contractor shall conduct historical program reviews of the funding that was provided via TEOAF’s financial plan to federal agencies for various law enforcement efforts.

2.A.1.1 - The Contractor will meet with TEOAF Management to determine the line items within each agency’s financial plan to be reviewed by the contractor.

The goals of each review will be to determine the adequacy of each agency’s accounting for and expenditure of Treasury Forfeiture funds and identify expenditures that may present a potential perception issue and/ or non-conforming.

2.A.2 - The contractor will be responsible for reviewing line-item expenditures in each of the following spending categories:

2.A.2.1 - Mandatory FY Spending Plans: Contractor shall perform a review of funding provided to TFF participating agencies in their Mandatory spending plans each fiscal year. The contractor will work with the Government to select a sample of line items for the review.

2.A.2.2 - Discretionary FY Spending Plans: Contractor shall perform a review of TFF participating agency’s Discretionary spending plans each fiscal year.

The contractor will work with the Government to select a sample offline items for the review.

2.A.3 – Contractor shall provide an annual report at the conclusion of each review to the COR for review and approval that shall include:

a) Summary of the task;

b) Strategy for task approach;

Task 2.B Major Case Technical Assistance and Forensic Accounting Support for

TEOAF and TFF Participating Agencies’ Field Offices (LH)

2.B.1 - Significant Money Laundering Investigation Technical Assistance - The Contractor shall provide technical assistance and support to the TFF participating agencies’ field offices and TFF agency Task Forces on major financial investigations. As directed by the COR, this task will require an initial assessment of each major case and a final summary of the technical support provided to the investigation2.

2.B.1.1 - A Significant Case is any complex financial investigation that could involve money laundering, major criminal networks, captured Banks/MSBs, or cryptocurrency. Case support is requested by the TFF participating agencies and approved in coordination with TEOAF.

2.B.1.2 - Assistance shall include the support developing major financial crime investigations by providing anti-money laundering subject matter expertise, technical, prosecutorial expertise, and/or banking industry expertise.

2B.1.3 – Provide TFF agency Task Force locations with subject matter expertise regarding money laundering methodologies, and scope and direction of investigation.

2.B.1.4 Participate in Quarterly meetings with the Government to discuss the current investigations being supported to include a synopsis of the investigation, the contractor support that has been provided, next steps for support, and any issues that are being encountered by the contractor.

2.B.1.5 This task may require occasional travel.

2.B.2 - Major Case Forensic Accounting Investigative Support - This task provides forensic accounting investigations of complex financial and business records to support Federal investigations and prosecutions. Support will be primarily used for non 3PML investigations OR in circumstances where the TEOAF contractor supporting the Financial Forensic Support (FFS) task order has a client conflict. As directed by the COR, this task will require an initial assessment of each major case

2 Examples of these reports can be provided by the COR and a final summary of the technical support provided to the investigation3.

The contractor shall provide the following support:

2.B.2.1 Use financial forensic skill sets to investigate and analyze all components of the financial infrastructure of MLOs, DTOs, and TCOs syndicates, their methods of criminal money movements, and the professional money laundering infrastructure facilitating these movements.

2.B.2.2 Participate in strategic planning sessions with financial investigative groups and task forces and assist Treasury and the DHS law enforcement agencies with conducting interviews during the course of the financial investigation.

2.B.2.3 Conduct analysis during the course of investigation support on financial transactions in order to accurately identify all parties involved in the criminal activity and conduct analysis and audit complex financial and business records to support Federal investigations and prosecutions.

2.B.2.4 Obtain raw criminal intelligence from various database resources and correlate the data, culminating in a full analysis of the information and input all researched and analyzed data into various professional products for statistical analysis data, intelligence summaries, and power point presentations for law enforcement use.

2.B.2.5 May serve as a factual witness during Federal prosecutions.

2.B.2.6 This task may require occasional travel.

2.B.3 - Strategic Technical Advisor - The Contractor shall provide technical assistance to TEOAF’s Strategic Planning Team. The Contractor shall provide the following support:

2.B.3.1 – Support reviews of third-party money laundering case submissions and 3PML Task Force designations. This task may require occasional travel to 3PML Task Force locations for on-site reviews.

2.B.3.2 – Support reviews of discretionary budget proposals from our TFF participating agencies.

2.B.4– Contractor shall provide a quarterly report to the COR and Strategic Planning and Analysis Team that shall include4:

a) Summary inventory chart demonstrating support provided to each TFF agency, by contractor;

b) Detailed summary of open assessments and actively support major case investigations;

3 Examples of these reports can be provided by the COR 4 Example of report can be provided by COR.

c) Pending investigations or other outstanding issues;

d) Support provided by the Strategic Technical Advisor.

Task 2.C Develop and Provide Training at TEOAF and TFF Participating Agency Conferences (LH)

2.C.1 – Contractor shall provide technical assistance and develop TEOAF approved training guides and curriculums for TEOAF staff and TFF participating agencies on money laundering typologies.

2.C.2 – Contractor shall provide technical assistance with the preparation and development of new training curriculums for TEOAF sponsored training and/or conferences or those held by the TFF participating law enforcement agencies.

Presentations shall cover, but not be inclusive to, the following money laundering typologies:

• TBML

• BMPE

• CMLO

• MSB

• Digital Currency and Online Payment Systems

• Shell Companies and Trusts

• Financial Institution Capture

2.C.2.1 - Each presentation must include case studies and investigative techniques relating to money laundering typologies.

2.C.2.2 - Contractor shall be responsible for constructing the presentation and all materials, such as training guides, required for this task.

2.C.3 - Provide a report at the conclusion of each training session to the COR for review and approval that shall include:

a) Copy of the training presentation and all training related materials created; and

b) Summary report outlining the training provided at the training session, if training session occurred.

2.C.4 – Contractor shall facilitate meetings and discussions between TEOAF and their member agencies to decided priority curriculums and determine the best approach for developing all necessary training.

Task 2.D Assessment of Strategic Planning and Analysis Activities (FFP)

2.D.1 – Contractor shall prepare mid-year and final reports summarizing all analysis and review performed by the Contractor for the Strategic Planning and Analysis Section.

2.D.1.1 - The mid-year report shall summarize all deliverables for the first half of the fiscal year and the final report shall summarize all deliverables for the entire fiscal year.

2.D.2 – Contractor shall provide a semiannual report to the COR for review and approval that shall include all findings, recommendations for areas of improvement, and any other identified issues already presented to the COR in the previously submitted deliverables. The report shall also address new comments and recommendations that need to be brought to the COR’s attention. The reports shall also include:

a) Summary of task;

b) Status of task; and

c) Any significant issues discovered during the Contractor’s performance of work.

C.3.3 TASK 3: GENERAL PROPERTY SUPPORT

The Contractor shall provide the following in support of the GP Contract:

Task 3.A Contract Invoice Review and Cost Analysis (FFP)

3.A.1 – Contractor shall provide technical assistance under this task through review of each GP Contractor invoice monthly or upon receipt if the invoice if it is not submitted on schedule by the GP Contractor. Invoice review should include identifying potential sample backup vendor invoice documentation requests, noting invoice trends or anomalies, and identifying visible invoice errors. Review should include a running cost comparison by contract year and TFF agency.

3.A.2 – Contractor shall provide a monthly findings report with submission of invoice that shall include:

a) Explanation of the Voucher submitted for review;

b) Costs billed to date for all open fiscal years;

c) Costs billed to date by the Agency; and

d) Costs billed to date by the Contractor.

Task 3.B Risk Management Oversight (LH)

3.B.1 – Contractor shall review and track all adverse incident reports provided by the GP COR to ensure:

3.B.1.1 - TEOAF management is aware of all material incidents

3.B.1.2 - Procedures can be implemented/changed as necessary to prevent similar occurrences in the future, and

3.B.1.3 - Adverse incidents, which may occur periodically, are appropriately resolved by the GP COR but shall be tracked monthly.

3.B.2.1 – Contractor shall provide a quarterly report to the COR for review that

1) A database is maintained and easily accessible by TEOAF personnel of all adverse incidents.

2) Share reports each quarter with the CORs and TEOAF Management to ensure they are aware of all material incidents;

3) Recommended procedures for TEOAF to implement/change as necessary to prevent similar occurrences in the future, and

4) Documentation that all incidents are appropriately resolved and acknowledged in report form.

Task 3.C Contract Revenue Testing GP (FFP)

3.C.1 – The Contractor shall, as requested by the COR, observe specific auctions, in-person and online, being held by the GP Contractor, to document adherence to the proper methods and handing of the property are being utilized as stated in the GP Performance Work Statement.

3.C.2 - The Contractor shall monitor and trace all collected revenue from each auction from the time the revenue is electronically transferred by the GP Contractor to the point where it is deposited to ARC.

3.C.3 - At the conclusion of each review, the Contractor shall provide a report to the GP COR for review and approval that shall include:

a) Summary of the task;

b) Explanation of the review process;

c) Identification of any issues;

Task 3.D Contract Inventory Testing of GP Report (LH)

3.D.1 - The Contractor shall conduct the following in support of GP Contract Inventory Testing:

The Contractor is responsible for all pre-planning necessary before travel commences to each inventory site, to include coordination with the GP COR who will be responsible for contacting all CSF and vehicle storage locations to finalize logistics for each inventory trip on behalf of the Contractor. The Contractor also shall prepare the SEACATS data provided by the GP COR before commencing travel to each inventory site. The Contractor shall reconcile inventory at all CSFs and other sub-contractor operated storage facilities (i.e. vehicle inventory storage locations) in the geographic proximity, as required. The Contractor shall select a representative sample for each location from the data provided by the GP COR to perform the inventory testing. When possible, the Contractor shall perform these tasks in conjunction with the GP Contractor’s Risk Management Team.

3.D.1.A Seizure File Review at Storage Facilities: The Contractor shall conduct a review of the electronic seizure files maintained at each location for which a review is being performed. The Contractor shall select a representative sample, and conduct a thorough analysis to ensure all proper documentation, information, and values are contained in each file.

3.D.1.B - High Risk Property Review: The Contractor shall review and reconcile inventory items deemed high risk for pilferage, including:

Review SEACATS count sheets to identify high risk items;

Conduct physical inventory and document discrepancies

Physically review warehouse inventory for evidence of tampering

Reconcile actual inventory count against SEACATS count sheets and data in physical files

Analyze and document any pertinent information uncovered

Conduct post-inventory SEACATS reconciliation.

3.D.2 – The Contractor shall provide a report at the end of each inventory review to the GP COR for review/approval that shall include:

a) Introduction of the report, including team members, the location where the inventory (including GFP/GFE) and the file reviews were conducted, security, and staffing;

b) The method of review used to perform the inventory testing;

c) Identification of all inventory issues;

d) Identification of all file review issues;

e) Final observations to TEOAF Property Team.

Task 3.E General Property Destruction Assessments (FFP)

3.E.1 - The Contractor shall identify destruction and recycling vendors, obtain SEACATS reports and Disposition Orders for Destruction/Recycling, identify upcoming destructions and recycling, for conducting testing and observing vendors with their destructions and recycling. Identify the vendors EPA has listed as certified recycling companies and verify if the General Property Contractor is utilizing them. Identify alternatives to destructions (e.g., identify allowable sales for export only).

3.E.2 - The Contractor shall conduct visitations to non-CSF storage facilities to observe destruction and recycling process. Compare seizure files and physical inventory to billing documents and SEACATS data to validate that storage invoices are based on legitimate assets in custody.

3.E.3 – The Contractor shall provide a report at the end of each destruction oversight to the GP COR that shall include:

a) Introduction of the report, including team members, the location where the destruction oversight was conducted, and staffing involved;

b) The method of review used to perform the destruction assessment;

c) Identification of all destruction issues;

d) Final observations to TEOAF Property Team.

Task 3.F General Property Contract Assessment and Operational Recommendation

Reports to TEOAF Management (FFP)

Prepare mid-year and end-of-year reports summarizing all analysis and review provided for the GP Contract. The mid-year report shall summarize all deliverables for the first half of the fiscal year and the final report shall summarize all deliverables for the entire fiscal year.

The reports shall be delivered to the COR semiannually and include all findings, recommendations for areas of improvement, any other identified issues already presented to the COR in the previously submitted deliverables, plus any new comments and recommendations that need to be brought to the COR’s attention.

The reports shall also include:

a) Introduction of the Report;

b) General Observations of Contractor performance;

c) Progress on previously identified Issues and recommendations, broken down by primary issues/vulnerabilities and secondary issues/vulnerabilities;

C.3.4 TASK 4: REAL PROPERTY (RP) CONTRACT SUPPORT

The Contractor shall provide the following in support of the RP Contract:

Task 4.A Contract Compliance and Review of the RP Contract Services (LH)

4.A.1 – The Contractor shall provide recommendations to address and resolve unanticipated cost or property management issues that arise during the normal course of business. Example topics may include the following:

a) Identification and review of unusual or high dollar expenditures

b) Review and analysis of RP contractor and subvendor operations

c) Random sampling of seizure folders

d) Review of RP that have been burglarized

e) Review of RP damaged during an act of God

4.A.2 – The Contractor shall provide a semiannual report to the Real Property COR for review/approval which shall include all findings, recommendations for areas of improvement, and any other identified issues previously presented to the RP COR in the previously submitted deliverables. The submitted report shall also include any new comments requiring the RP COR’s attention.

a) Summary of the task;

b) Explanation of the review process;

d) Conclusions

Task 4.B Contract Invoice Review and Cost Analysis (FFP)

4.B.1 – The Contractor shall provide technical assistance under this task through review of each RP Contractor invoice received. Each invoice will be reviewed and analysis will be provided in a monthly report. Invoice review should include identifying potential sample sub-contractor invoice documentation requests, noting invoice trends or anomalies, and identifying visible invoice errors.

4.B.2 – The Contractor shall provide a monthly findings report for invoices submitted during the prior month that shall include::

a) Explanation of the voucher submitted for review;

b) Contract funding tracking;

c) Contract spending/burn rate computation per CLIN;

d) Stratified and random sampling review of supporting documentation for sub-contractor expenses per CLIN; and

e) Identification of invoice trends, anomalies, and visible invoice errors.

Task 4.C Contract Revenue Testing Report (FFP)

4.C.1 – The Contractor shall, as requested by the COR, observe specific live and online auctions, general and special, being held by the RP Contractor, to document adherence to the proper methods and handing of the property are being utilized as stated in the RP Performance Work Statement.

4.C.2 - The Contractor shall monitor and trace all collected revenue from each auction from the time the revenue is electronically transferred by the RP Contractor to the point where it is deposited at ARC.

Note: A schedule is not issued for real property auctions. Auctions occur as the properties are cleared of liens and can either be live, at the location of the property, or take place over the internet.

4.C.3 - At the conclusion of each review, the Contractor shall provide a report to the RP COR for review and approval that shall include:

a) Summary of the task;

b) Explanation of the review process;

c) Identification of any issues;

Task 4.D Audit Reconciliations of all TFF Agency Seized Real Property Report (FFP)

4.D.1 – The Contractor shall perform a quarterly review of seized real property records by the following TFF participating agencies: ICE, IRS-CI, and USSS. The electronic records are received from these agencies and are maintained by TEOAF.

The Contractor shall compare the seized property records of each agency, as shown on their individual record keeping systems, to the seizures reported on SEACATS.

The Contractor shall use Roll Forward Exhibit 5 when performing the reconciliation to identify inconsistencies.

4.D.2 - At the conclusion of each review, the Contractor shall provide a report to the RP COR for review/approval that shall include:

a) Each agency’s reconciliation;

b) Specific issues that were addressed;

c) A summary of findings;

d) A completed Annual Audit Exhibit 5 for each agency

Task 4.E RP Contract Assessment and Recommendation Reports to TEOAF

Management (FFP)

4.E.1 – The Contractor shall prepare mid-year and end-of-year reports summarizing all analysis and review provided for the RP Contract. The mid-year report shall summarize all deliverables for the first half of the fiscal year and the final report shall summarize all deliverables for the entire fiscal year.

4.E.2 - The reports shall be delivered to the COR semiannually and include all findings, recommendations for areas of improvement, any other identified issues already presented to the COR in the previously submitted deliverables, plus any new comments and recommendations that need to be brought to the COR’s attention. The reports shall also include:

a) Introduction of the Report;

b) General Observations of Contractor performance;

c) Progress on previously identified Issues and recommendations, broken down by primary issues/vulnerabilities and secondary issues/vulnerabilities;

C.3.5 TASK 5: AD-HOC Support to All TEOAF Programs

Task 5.A Capabilities and resource needs associated with various program areas supported by TFF. (LH)

5.A.1 - The Contractor shall, as requested by the COR, provide expanded technical assistance to TEOAF within the areas of Financial Management, Strategic Support, or Seized Property on an as needed basis. Upon request and approval by the COR, the Contractor will provide their expertise for unanticipated surge support requirements related to the workload listed in the sections above.

C.3.6 PERFORMANCE REQUIRMENTS SUMMARY (PRS)

Required Service Performance Standards

Acceptable Quality Levels

Method Of

Surveillance

Incentive (Negative) (Impact on Contractor Payments)

Communicate effectively with TEOAF Management, COTR and Staff

Effective Communication Replies to email requests for activity or work product within 24 hours

100% Files review, periodic, random, observations

Contractual remedies

Provide Technical Assistance to the Financial Management Team

Compliance Review of Equitable Sharing Program

Obligation Reconciliation of Equitable Sharing and Refund Payments

Review of TFF Agency Obligations, Reimbursables and Expenditures

Technical Assistance for Package Review for Equitable Sharing, Refunds, and Joint Operations

Reimbursement

Delivers completed report timely as addressed in the associated Task

Order PWS; Addresses questions or requests from the Government within 5 business days.

Delivers completed report timely as addressed in the associated Task

Order PWS; Addresses questions or requests from the Government within 5 business days.

Delivers completed report timely as addressed in the associated Task

Order PWS; Addresses questions or requests from the Government within 5 business days.

Performs activity within the timeframe directed by the

Government; Delivers completed report timely as addressed in the associated Task Order PWS;

Addresses questions or requests from the Government within 5 business days.

99%

99%

99%

95%

File reviews, periodic, random, observations

File reviews, periodic, random, observations

File reviews, periodic, random, observations

File reviews, periodic, random, observations

Contractual remedies

Contractual remedies

Contractual remedies

Contractual remedies

Provide Technical Assistance to the Strategic Planning and Analysis Team

TEOAF Program Reviews

Technical Assistance monitoring the TFF Agency’s Major Case Activity

Assistance with Providing Training at TEOAF and TFF Participating Agency

Conferences

Assessment of Strategic Planning and Analysis Activities

Delivers completed report timely as addressed in the associated Task

Order PWS; Addresses questions or requests from the Government within 5 business days.

Delivers completed report timely as addressed in the associated Task

Order PWS; Addresses questions or requests from the Government within 5 business days.

Delivers completed report timely as addressed in the associated Task

Order PWS; Addresses questions or requests from the Government within 5 business days.

Performs activity within the timeframe directed by the

Government; Delivers completed report timely as addressed in the associated Task Order PWS;

Addresses questions or requests from the Government within 5 business days.

95%

95%

95%

95%

File reviews, periodic, random, observations

File reviews, periodic, random, observations

Periodic, random, observations, complaints

File reviews, periodic, random, observations

Contractual remedies

Contractual remedies

Contractual remedies

Contractual remedies

Provide Technical Assistance to the COTR of the General Property Contract

Contract Invoice Review and Cost Analysis

Risk Management Oversight

Contract Revenue Testing GP

Contract Inventory Testing of General Property

Delivers completed report timely as addressed in the associated Task

Order PWS; Addresses questions or requests from the Government within 5 business days.

Delivers completed report timely as addressed in the associated Task

Order PWS; Addresses questions or requests from the Government within 5 business days.

Performs activity within the timeframe directed by the

Government; Delivers completed report timely as addressed in the associated Task Order PWS;

Addresses questions or requests from the Government within 5 business days.

Performs activity within the timeframe directed by the

Government; Delivers completed report timely as addressed in the associated Task Order PWS;

Addresses questions or requests from the Government within 15 business days.

95%

95%

95%

99%

File reviews, periodic, random, observations

File reviews, periodic, random, observations

Periodic, random, observations, Periodic, random, observations

Contractual remedies

Contractual remedies

Contractual remedies

Contractual remedies

Oversight and Assessment of General

Property Destructions

Contract Assessment and Recommendation Reports to TEOAF Management

Performs activity within the timeframe directed by the

Government; Delivers completed report timely as addressed in the associated Task Order PWS;

Addresses questions or requests from the Government within 10 business days.

Delivers completed report timely as addressed in the associated Task

Order PWS; Addresses questions or requests from the Government within 15 business days.

99%

95%

Periodic, random, observations

File reviews, periodic, random, observations

Contractual

Provide Technical Assistance to the COTR of the Real Property Contract

Contract Compliance, Review and

Oversight

Contract Invoice Review and Cost Analysis

Contract Revenue Testing RP

Audit Reconciliations of all TFF Agency Seized Real Property Report

Contract Assessment and

Recommendation Reports to TEOAF Management

Timely response to all email requests for activity or work product with 24 hours.

Order PWS; Addresses questions or within 5 business days.

Government; Delivers completed report timely as addressed in the associated Task Order PWS;

Addresses questions or requests from the Government within 5

Government; Delivers completed report timely as addressed in the associated Task Order PWS;

Addresses questions or requests from the Government within 5

Order PWS; Addresses questions or within 15 business days.

99%

Provide Ad-Hoc Support to All TEOAF Programs

Assessments of TEOAF Programs Performs activity within the timeframe directed by the

Government; Delivers completed report timely as addressed in the associated Task Order PWS;

Addresses questions or requests from the Government within 5 business days.

95% Periodic, random observations

Contractual remedies

C.4 LABOR CATEGORIES

C.4.1. Program Manager (PM)

Professional holding a BA/BS and 10+ years of relevant experience, managerial, functional and technical, in the following subject areas:

• Business process improvement

• Performance assessment

• Operations improvement

• Financial management and planning

• Program management

Additionally, this position requires 5-10 years of relevant experience, managerial, functional and technical, in the following subject area:

• Asset Forfeiture

Successful candidates must have a strong background in program/project management, project design and execution, documentation, quality assurance of deliverables, and the financial management and administration of projects; as well as leadership, communication skills, broad software skills and the ability to execute high level written communications and documentation.

Technical experience specific to the field of asset forfeiture must include: familiarity with federal forfeiture statutes, court cases, trends and policies dealing with asset forfeiture, auditing and analysis of processes, procedures and compliance, risk management, inventory testing and record keeping and invoicing and payments.

C.4.2 Senior Consultant II (SC II)

A Certified Public Accountant or Certified Internal Auditor in good standing with a minimum five years of audit experience including two years with federal government in leading and providing technical assistance to compliance audits.

Desired qualifications include:

• Experience with auditing and analysis of processes, procedures and compliance.

• Knowledgeable in GAO Government Auditing Standards; OMB Circulars A-11

Preparation and Submission of Budget Estimates; and A-123 Management’s Responsibility for Internal Control; A-134 Financial Accounting Principles and Standards;

A-136 Financial Reporting Requirements; Digital Accountability and Transparency Act of 2014 and Improper Payments Elimination and Recovery Improvement Act of 2012.

Successful candidates must also demonstrate experience with independent performance of required work assignments, process mapping and workflow documentation, work plan development, system requirements analysis; evidence of effective communication skills, broad software skills and the ability to execute high level written communications and documentation.

C.4.3 Senior Consultant (SC)

Professional holding a BA/BS and 10+ years of relevant experience, functional and technical, in the following subject areas:

• Asset forfeiture;

• Performance assessment;

• Financial management and planning; and/or

• Federal and/or state level prosecutorial support

Additionally, this position requires 5-10 years of relevant experience, managerial, functional and technical, in the following subject areas:

• Operations improvement;

• Program management;

• Risk management and compliance

Technical experience specific to the field of asset forfeiture must include: experience with complex financial investigations, analysis of financial records, supporting federal and/or state level prosecutions, preparing reports and…