Supply Chain Analysis

FOCI and Compliance Risk

Department of Veterans Affairs

Updated March 2024

Primes with 889 or 1260H Compliance Violations

3,398

Chinese Connected Tier 1 Suppliers

Primes with Chinese Connected Owners or Investors

777

Active Contracts over $10M

FOCI and Compliance Risk: VA

Ark.ai conducted a supply chain analysis of the Department of Veterans Affairs, 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 VA resulted in the following statistics. There are 3 Primes with 889 or 1260H Compliance Violations. The count of Chinese Connected Tier 1 Suppliers is 3,398 and the number of Primes with Chinese Connected Owners or Investors is 64.

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
Cepheid	$467,879,925	1758	1
Beckman Coulter, Inc.	$262,123,333	2777	1
Leica Microsystems Inc	$16,241,133	453	1
Beckman Coulter, Inc.	$5,424,054	192	1
Radiometer America Inc.	$3,413,202	190	1

Top Common Tier 1 Suppliers

Name	Count of Common Primes	Dollars Awarded to Primes	Count of Prime Contracts
Pfizer Inc.	57	$268,626	1,777,625
Carahsoft Technology Corp.	49	$23,228,156	1,692,379
Regents of The University of Michigan	45	$13,770,211	13,964
University of Washington	44	$28,156,216	15,367
General Electric Company	44	$18,272	191,484

Top Contracts with Chinese Connected Suppliers

Contract ID	Supplier Name	Dollars Awarded	Funding Office
36C10G20K0074	Government of China	$325,344,106	STRATEGIC ACQ FREDERICKSBURG
36C10G22K0070	Government of China	$279,803,103	NF/SG VETS HOSP
36C10G21K9961	Government of China	$279,488,672	NF/SG VETS HOSP
36L79722C0003	Castic SMP Machinery Co Ltd	$16,060,784	NAC LAUNDRY AND PACS
36H79720C0006	Castic SMP Machinery Co Ltd	$13,898,673	NAC HIGH TECH CTR

Top Primes with Non-U.S. Revenue Greater than 50%

Name	Non-US Revenue %	Dollars Awarded	Primary Funding Office
Varian Medical Systems, Inc.	55.9%	$184,858,685	DEPT OF VA
3M Company	57.6%	$67,120,792	ASPR / DAAPPO / BARDA DCMA
Invacare Corp	65.4%	$24,285,575	HHS/PUBLIC HEALTH SERV
Accuray Inc	76.0%	$17,800,118	NAC HIGH TECH ORDERS
Abbott Lab	61.4%	$3,418,429	ASPR / DAAPPO / BARDA DCMA

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.