Supply Chain Analysis

FOCI and Compliance Risk

Department of Commerce

Updated March 2024

Primes with 889 or 1260H Compliance Violations

1,646

Chinese Connected Tier 1 Suppliers

Primes with Chinese Connected Owners or Investors

244

Active Contracts over $10M

FOCI and Compliance Risk: Commerce

Ark.ai conducted a supply chain analysis of the Department of Commerce, examining the vendors supporting the agency and their subcontractors, subsidiaries, list of suppliers, manufacturers, shippers, and other members of the supply chain. The resulting supplier analysis and supplier profile includes a compliance analysis, an evaluation of foreign ownership and investment, and a comprehensive assessment of compliance risk and FOCI risk.

The analysis of Commerce resulted in the following statistics. There are 3 Primes with 889 or 1260H Compliance Violations. The count of Chinese Connected Tier 1 Suppliers is 1,646 and the number of Primes with Chinese Connected Owners or Investors is 9.

Information about vendors with compliance violations, Chinese connections, and other supply chain risks are included in the following tables.

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Top Companies with 889 or 1260H Violations

Name	Dollars Awarded	Count of Awards	Count of Violations
Sea-Bird Electronics, Inc.	$16,832,211	319	3
OTT Hydromet Corp	$5,793,192	77	9
AB Sciex LLC	$1,699,405	23	5
Beckman Coulter, Inc.	$659,570	17	13
Leica Microsystems Inc.	$341,506	18	14

Top Common Tier 1 Suppliers

Name	Count of Common Primes	Dollars Awarded to Primes	Count of Prime Contracts
Carahsoft Technology Corp.	79	$57,015,093	1,627,361
CDW Government LLC	63	$428,568,345	556,364
Dell Federal Systems L.P.	57	$271,699,543	189,116
Dell Marketing L.P.	54	$36,415	41,244
Microsoft Corporation	54	$15,048	36,130

Top Contracts with Chinese Connected Suppliers

Contract ID	Supplier Name	Dollars Awarded	Funding Office
1333BJ23F00280043	Changzhou Runfu Electron Co Ltd	$621,546	Patent and Trademark Office
1333LB21F00000328	Suzhou Furukawa Power Optic Cable Co Ltd	$351,540	Census
1305M319CNWWG0036	ETS Solutions China Ltd	$253,872	NOAA
1333LB21F00000025	Shanghai Aerotech Trading International Co Ltd	$242,456	Census
1305M322CNRMA0034	Professional Diversity Network Inc	$236,230	NOAA

Top Primes with Non-U.S. Revenue

Name	Non-US Revenue %	Dollars Awarded	Primary Funding Office
John Wiley and Sons Inc	51.40%	$4,758,460	NIH OLAO
KLA Corp	88.90%	$2,959,234	NIST
Ansys Inc	54.50%	$1,642,152	NASA SSC
Coherent Inc	77.40%	$1,473,597	NRL
IPG Photonics Corp	76.30%	$854,571	NSWC Dahlgren

ABOUT FOCI AND COMPLIANCE RISK

Uncover foreign influence in vendor ecosystem across investors, ownership, key personnel, and geographic locations and unearth organizations in your ecosystem that are non-compliant with U.S. legislative regulations such as Section 889 or 1260H.

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EXPLORE ADDITIONAL ANALYSES

ABOUT ARK.AI

The Ark is the only software platform purpose-built for Defense Acquisition that leverages authoritative commercial data and AI-enabled Applications designed to solve Acquisition challenges. With the Ark, analysts and decision-makers gain the ability to manage Acquisition programs proactively, allowing them to unwind the legacy complexity and effectively field modern warfighting systems that compete with China.

The Leading Defense Acquisition Software.

OUR APPLICATIONS

AI-enabled Applications within The Ark reflect standard workflows across the Defense Acquisition Process. From Science & Technology to Modernization, these Applications allow for the execution of rapid, efficient, data-informed decisions, standardized reporting, and efficient workflow management. The Ark enables your team to transform Defense Acquisition into a strategic advantage.