Cap Table Assessment Know your investors: Where are your investors headquartered? Who are the key stakeholders in that business? Do any individuals have potential foreign countries of concern affiliations? Are there any agreements with investors regarding IP that increases malign tech transfer risk? Employee Assessment Know your employees: Do your company executives or individuals involved
Due Diligence
What tools does Army SBIR|STTR employ when conducting due diligence?
The Army SBIR|STTR Due Diligence Team uses a combination of publicly available information, open-source research, and commercially available information through our data providers, along with company disclosures.
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If I have foreign countries of concern investment or an individual working on the project team with a foreign country of concern affiliation (e.g., co-authorship, funding, etc.), is my proposal automatically denied?
No – the Army SBIR|STTR Due Diligence Team will independently assess each proposal using the standard due diligence process. For proposals exhibiting significant risk indicators, such as covered individuals with foreign countries of concern affiliations or investment, the due diligence team will conduct enhanced deep-dive due diligence reviews on the indicated risk and overall proposal.
What risk factors does the Army SBIR|STTR Due Diligence Team assess?
The Army SBIR|STTR Due Diligence Team primarily focuses on malign tech transfer risk stemming from indications of Foreign Ownership, Control, or Influence. The team also considers risk stemming from fraud, waste and abuse, cybersecurity, and other business risk factors.
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How does the Army SBIR|STTR due diligence process work?
The Army SBIR|STTR Due Diligence Team assesses both company disclosures and business intelligence data through our providers. Once a small business submits a proposal via DSIP, the team identifies any discrepancies between the forms, and/or foreign nexus, and/or other business concerns from the business intelligence data to produce a Secondary Review report. The team uses
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What law and policy guides the Army SBIR|STTR Due Diligence Team?
The SBIR and STTR Extension Act of 2022 (Public Law 117-183) establishes the Army SBIR|STTR Due Diligence Team. “Assess, using a risk-based approach in accordance with (IAW) references a and b, the cybersecurity practices, patent analysis, employee analysis, and foreign ownership, interests, partnerships, and associations of a small business concern seeking a SBIR/STTR award, including
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What is due diligence?
Due diligence is a risk assessment to protect U.S. intellectual property and defense capabilities. The due diligence investigation confirms or denies reported interests and associations and uncovers unreported factors representing potential conflicts of commitment or interest. As it pertains to congressional requirements for the SBIR and STTR Programs, due diligence primarily focuses on confirming, denying,
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