INVESTIGATIVE INTELLIGENCE BRIEF

Date of Briefing: 2026-10-02
Subject: Booz Allen Hamilton (BAH) — Federal Procurement Mechanics, Financial Flows, and Influence Ecosystem
Data Baseline: 280 unique records (212 primary-source records, 80 inferential records, 39 documented connections)

1. CONFIRMED PRIMARY-SOURCE FACTS

Grouped by entity and verified against primary-source disclosures (SEC filings, LDA filings, FEC records, court records, statutory and regulatory authorities).

Booz Allen Hamilton Inc. (Corporate, Financial, and Contract Disclosures)

Federal Government Agencies & Regulatory Frameworks

• Statutory Procurement Transparency Carve-Outs:
  • 41 U.S.C. § 4702(b): Exempts specified intelligence activities from the Federal Funding Accountability and Transparency Act (FFATA), providing statutory authority to exclude intelligence agency contracts from USASpending display (further affirmed in GAO-12-263 and GAO-23-106101 regarding NSA/NRO reporting exceptions).
  • FAR 4.603(b) & FAR 4.1403(c)(2): Directs that while classified contracts are reported to FPDS-NG (DFARS 204.6), they are excluded from public transparency platforms.
  • FAR 17.700: Exempts nondefense elements of the Intelligence Community from standard nondefense agency joint contracting rules.
  • FAR Subpart 16.5 & FAR 8.4: Permits delivery orders against GSA Schedules (e.g., GS-35F-0138U, GS-10F-044TA) and IDIQs to satisfy "fair opportunity" rules with a single bidder.
• Other Transaction Authority (OTA) Expansions:
  • FY2021 NDAA (§ 804): Explicitly expanded DoD OTA use to cyberspace operations (enacted Jan 1, 2021).
  • FY2022 NDAA (§ 844 & § 852): Section 844 raised the follow-on production prototype OTA threshold from $100M to $500M without requiring standard FAR Part 15 competition. Section 852 authorized an OTA cybersecurity pilot exempt from 41 U.S.C. § 1703 USASpending posting requirements.
• Lobbying Disclosure Act (LDA) Carve-Outs:
  • 2 U.S.C. § 1603(9): Classifies and exempts communications regarding classified programs from registration and reporting requirements.
• CISA & Executive Order 14028:
  • EO 14028 (May 12, 2021) expanded federal civilian cybersecurity requirements and referenced existing FISMA/FAR frameworks. Section 7 mandated the CDM program as an implementation baseline.
  • CISA’s FY2024 enacted budget reached $3.37B (an 8.7% increase over FY2023 enacted level of $3.1B, per the DHS Budget in Brief).

Industry Trade Associations & Peer Comparisons

• Professional Services Council (PSC): Operates the Defense and Intelligence Council (DIC, formed June 2014; Ryan McDermott served as VP for Defense & Intelligence from Dec 2017). Annual LDA expenditures ranged between $1.0M and $1.8M (2020–2024). Former BAH General Counsel CG Appleby (2005–2006) and EVP Trey Obering (2017) previously served on PSC leadership bodies; no BAH executives appear on published 2024–2026 rosters.
• Intelligence and National Security Alliance (INSA): Files quarterly LD-2 disclosures under issue codes CSP, INT, BUD, and GOV. Hosts the annual Intelligence and National Security Summit.
• Peer SEC Disclosure Practices: Competitors Leidos, CACI International, SAIC, and Parsons Corporation have explicitly filed or referenced SEC confidential treatment requests (e.g., Rule 24b-2 or Rule 406) for classified segments in their Form 10-K/10-Q filings (2020–2025).

2. KEY FINANCIAL & POLITICAL FLOWS

+-----------------------------------------------------------------------------------------+
|                                 POLITICAL CONTRIBUTIONS                                 |
|                                                                                         |
|  BAH Political Action Committee (PAC ID: C00709816)                                     |
|     |                                                                                   |
|     +--> Total Contributions (2023–2024 Cycle): $336,500                                 |
|     |      (Peer context: SAIC $415K; Leidos $308K; CACI $273K)                         |
|     |                                                                                   |
|     +--> Dale W. Strong (U.S. Representative): Backed 2026 reelection bid               |
+-----------------------------------------------------------------------------------------+

+-----------------------------------------------------------------------------------------+
|                                DIRECT LOBBYING EXPENDITURES                             |
|                                                                                         |
|  Booz Allen Hamilton Direct Federal Lobbying (LD-2 Filings)                              |
|     |-- FY2022: Retained Akin Gump (Q2 2022) on antitrust policy for EverWatch deal     |
|     |-- FY2023 Total: $620,000                                                          |
|     |-- FY2024 Total: $1.67M (Q1 2024: $170K on "federal procurement policy")           |
|     |-- FY2025 Total: $1.83M (Q2 2025: $650K alone; issue codes: NDAA FY26, cyber,     |
|     |                         federal cyber workforce, missile defense)                 |
+-----------------------------------------------------------------------------------------+

+-----------------------------------------------------------------------------------------+
|                                 PRIME CONTRACT CASH FLOWS                               |
|                                                                                         |
|  Federal Agencies / Vehicles                     Obligated / Ceiling Amounts            |
|  ----------------------------------------------  -------------------------------------  |
|  SOCOM eMAPS (N6600118C4505 via ODO)             $885M initial ($1.2B current ceiling)  |
|  DARPA TASS IDIQ                                 ~$160M obligated (Deltek)              |
|  DHS CDM DEFEND Group B                          $621M                                  |
|  DHS CDM DEFEND Group D                          $1.03B                                 |
|  DHS CISA Delivery Order 70RCSA20FR0000099       $55.5M                                 |
|  DHS CDM Cyber Analytics & Resiliency            $90M                                   |
|  DISA EIS Transition Support (HS0021-20-QA001)   $485M ceiling                          |
|  DHS OTA Cybersecurity Analytics                 $7.5M                                  |
+-----------------------------------------------------------------------------------------+

+-----------------------------------------------------------------------------------------+
|                              CORPORATE ACQUISITIONS CAPITAL                             |
|                                                                                         |
|  KEYW Corporation (May 2019): $602M all-cash acquisition                                |
|  EverWatch (Dec 2022): ~$440M transaction value                                         |
+-----------------------------------------------------------------------------------------+

3. NETWORK CONNECTIONS

                     +---------------------------------------+
                     |        BOOZ ALLEN HAMILTON            |
                     |         (Central Node / Hub)          |
                     +---------------------------------------+
                        |         |          |          |
        +---------------+         |          |          +------------------+
        |                         |          |                             |
        v                         v          v                             v
+----------------+      +---------------+  +------------------+   +-------------------+
|   DEFENSE /    |      |  CIVILIAN /   |  |   INFLUENCE &    |   |     INDUSTRY      |
|   INTEL HUBS   |      |  CYBER HUBS   |  |   TRADE BODIES   |   |    PEERS / M&A    |
+----------------+      +---------------+  +------------------+   +-------------------+
| SOCOM          |      | CISA / DHS    |  | PSC              |   | EverWatch         |
| NSA            |      | DISA          |  | INSA             |   |   (Acquired 2022) |
| DARPA          |      | CFO Act       |  | Akin Gump        |   | KEYW Corp         |
| CIA            |      |   Agencies    |  |   (Lobbying firm)|   |   (Acquired 2019) |
| NRO / NGA      |      |               |  | BAH PAC          |   | Leidos / CACI /   |
| C5 / NSTXL /   |      |               |  |   (C00709816)    |   |   SAIC / GDIT     |
|   DIU Consortia|      |               |  |                  |   |   (Competitors)   |
+----------------+      +---------------+  +------------------+   +-------------------+

Relationship Characterization

1. Primary Structural Hub: Booz Allen Hamilton sits at the intersection of defense, national intelligence, civilian agency shared services, and acquisition policy.
2. Strongest Direct Documented Operational Links:
   • DHS / CISA: Deep enterprise incumbency via CDM DEFEND Groups B ($621M) and D ($1.03B), covering ~80% of civilian executive agencies.
   • USSOCOM: Long-term analytics partner via the $885M–$1.2B eMAPS AI platform.
   • DARPA: Dominant position on TASS (~$160M obligations).
   • DISA: Incumbent enterprise transition contractor under EIS ($485M ceiling).
3. Indirect / Traceable Institutional Vectors:
   • PSC & INSA: Industry policy representation. While BAH’s direct lobbying ($1.5M–$1.8M/yr) mirrors services pure-plays (SAIC, CACI) rather than primes (Lockheed, RTX at $13M–$15M), BAH exercises indirect policy advocacy through PSC (Defense and Intelligence Council, former BAH personnel Ryan McDermott) and INSA summits, masking firm-specific legislative advocacy behind joint trade positions.
   • Congressional Appropriators: Direct political giving via PAC C00709816 targeting key oversight leaders, including Representative Dale W. Strong.

4. INFERENTIAL CLAIMS

All statements below are analytical inferences derived from the underlying facts. Each inference is assigned an explicit confidence rating and complies with strict absence-of-evidence verification standards.

Inferences Regarding Federal Contracting & Financial Reporting Opacity

• [INFERENCE — HIGH CONFIDENCE] Structural Partitioning of Classified Contract Revenue:
  Evidence: Booz Allen reported $10.7B in FY2024 revenue ($10B government-adjacent), while public USASpending obligations totaled $6.2B. The company disclosed $4.6B in classified backlog and 16–17% (~$1.81B) in Intelligence client revenue.
  Deduction: The ~$4.1B–$4.5B differential between visible USASpending obligations and total government revenue is explained by a combination of classified task orders exempt from public posting under 41 U.S.C. § 4702(b), unclassified OTA consortium pass-throughs, and multi-tier subcontracts.
• [INFERENCE — MEDIUM CONFIDENCE] Strategic Use of Other Transaction Authority (OTA) to Suppress Public Scrutiny:
  Evidence: DoD OTA obligations grew by 249% between FY2019 and FY2022. BAH lobbied continuously on NDAA acquisition reform and OTA threshold expansions (Sections 804 and 844), raising the non-competitive follow-on production limit to $500M. In FY2022 SEC filings, BAH cited OTA dependency for sensitive national security clients as a material risk factor representing >30% of revenue for certain accounts.
  Deduction: BAH actively channeled classified prototyping and cybersecurity pipelines into OTAs (e.g., C5, NSTXL, SOCOM eMAPS) to limit exposure to standard FAR Part 15 competition and FPDS-NG public posting.
• [INFERENCE — HIGH CONFIDENCE] Incumbent Modification vs. New Solicitation Under Executive Order 14028:
  Evidence: EO 14028 was signed May 12, 2021. Booz Allen received delivery order awards weeks later (May 28, 2021) and held existing civilian cybersecurity vehicles (OASIS delivery order 70RCSA20FR0000099, CDM DEFEND Groups B/D).
  Deduction: Work attributed to EO 14028 did not require new competitive contracting solicitations; CISA utilized existing in-scope task order modifications under BAH’s pre-existing IDIQ/BPA contracts.

Strict Application of Absence-of-Evidence Rules

Case A: Initial Zero-Result Searches for Booz Allen Hamilton on USASpending.gov

1. Expected Baseline Rate: A publicly traded defense contractor with $10B+ in annual federal business, holding top GSA Schedule 70 and MOBIS contracts, generates tens of thousands of transaction records annually in USASpending.
2. Nature of Deviation: The database logged initial automated test runs returning zero records.
3. Mundane Explanations Evaluated & Confirmed:
   • Identifier Discontinuity: GSA SAM.gov transitioned from DUNS (006928857) to UEI (FD1RV9USW1Y5) in April 2022, creating query failures on legacy databases.
   • Corporate Name Fragmentation: Contracts prior to 2008 were executed under "Booz Allen & Hamilton Inc." (ampersand), which fails fuzzy matching against "Booz Allen Hamilton Inc."
   • CAGE Code Multiplicity: BAH maintains at least 9 distinct CAGE codes (17038, 1B3A2, 3QEW9, 33QY3, etc.). A search restricted to the parent name or an unmapped subsidiary fails to capture aggregated spending.
   • Order Type Filter Architecture: Task orders under GSA Schedules (FAR 8.4) roll up under parent IDV PIIDs and are often omitted in default USASpending views unless filtered by delivery order.
   • Conclusion: The zero-result finding represents a technical search limitation, not government concealment or absence of contracting.

Case B: Purported Gaps in SEC EDGAR Filings (2017, 2021, 2022, 2024)

1. Expected Baseline Rate: As an SEC Large Accelerated Filer (CIK 0001443646), BAH is legally mandated under the Securities Exchange Act of 1934 to file Form 10-K annually within 60 days of its fiscal year-end (late May).
2. Nature of Deviation: Certain secondary database entries asserted missing 10-K filings for 2017, 2021, 2022, and 2024 (a purported 40% non-compliance rate).
3. Mundane Explanations Evaluated & Confirmed:
   • Primary SEC EDGAR verification confirms BAH filed Form 10-K on schedule in late May every single year from 2016 through 2025 without omission (e.g., FY2022 filed May 20, 2022; FY2024 filed May 24, 2024 under accession 0001443646-24-000010).
   • The purported "gaps" in the research database represent unhandled ingestion errors or archival API mismatches within internal query routines.
   • Conclusion: The claim of an SEC filing hiatus is factually refuted by primary EDGAR records.

Case C: Apparent Lack of Direct Classified Lobbying Disclosures

1. Expected Baseline Rate: Top-tier federal contractors maintaining multi-billion-dollar defense lines file regular LDA LD-2 disclosures.
2. Nature of Deviation: BAH’s LD-2 disclosures list broad issue codes (DEF, CYB, BUD, APP) without mentioning classified programs (e.g., NSA signals intelligence, CIA cloud).
3. Mundane Explanations Evaluated & Confirmed:
   • Under 2 U.S.C. § 1603(9), classified communications are exempt from lobbying disclosure.
   • Reporting classified program titles on public LD-2 forms would violate federal classification laws (EO 13526).
   • Conclusion: The absence of classified terms on LD-2 disclosures is legally mandated, not a compliance omission.

5. GAPS & CONTRADICTIONS

1. Direct Contradictions in Source Data

• SEC Filing Continuity vs. Documented Gaps:
  • Contradiction: Primary records #60, #61, #64, and #71 allege confirmed SEC filing gaps in 2017, 2021, 2022, and 2024.
  • Resolution: Primary record #149 and EDGAR data explicitly demonstrate unbroken annual 10-K filings in late May from 2016 to 2025. The recorded "gaps" are data-pipeline ingestion errors.
• Customer Segment Revenue Attribution (35% Metric):
  • Contradiction: Early investigative claims asserted that the Intelligence Community accounts for 35% of BAH’s revenue.
  • Resolution: Official SEC 10-K filings and the FY2025 performance update confirm the revenue mix is 49% Defense, 35% Civil, and 16–17% Intelligence ($1.81B in FY2024). The 35% figure belongs to Civil clients, not the Intelligence Community.
• CISA FY2024 Budget Growth:
  • Contradiction: Database fact #166 asserted a 15% budget increase for CISA in FY2024.
  • Resolution: Official DHS Budget in Brief records document an enacted budget increase of 8.7% ($3.1B to $3.37B).
• Corporate Governance Claims (PSC Board Chair):
  • Contradiction: Inferential facts #37 and #38 asserted BAH CEO Horacio Rozanski chaired the Professional Services Council in 2023–2024.
  • Resolution: Primary fact #51 shows BAH had past leadership on PSC (Appleby in 2005; Obering in 2017), but public rosters for 2024–2026 show no BAH executives on the Board or Executive Committee. Rozanski's purported chairmanship remains unverified by PSC IRS Form 990 or corporate press releases.

2. Search Scope Limitations vs. True Evidence of Absence

• "No Records" in Federal Procurement Queries:
  Initial search misses on USASpending.gov were caused by querying "Booz Allen Hamilton" without capturing legacy entity names ("Booz Allen & Hamilton Inc."), unlinked subsidiary CAGE codes (1B3A2, 3M3U7), or using the pre-2022 DUNS number post-UEI transition. When queried by UEI (FD1RV9USW1Y5) and primary CAGE (17038), billions in obligations appear.
• Missing Program Names ("Cryptologic Carry-All"):
  The purported "Cryptologic Carry-All" program yielded zero public records because it is either an internal/classified code name or a conflation with the Navy's unclassified "Cryptologic Carry-On Program" (CCOP) managed by NAVIFOR.

6. RECOMMENDED RESEARCH DIRECTIONS

To resolve open questions, the following targeted document acquisitions and cross-referencing steps are recommended:

1. Corporate Subsidiary Mapping:
   • Retrieve the complete Exhibit 21.1 from Booz Allen Hamilton’s latest Form 10-K and reconcile all six listed corporate entities against SAM.gov to extract their associated UEIs and CAGE codes (specifically isolating legacy KEYW CAGEs 3M3U7, 0V7F1 and EverWatch entities).
2. Programmatic USASpending API Pull:
   • Execute an automated multi-entity query via the USASpending API v2 combining UEIs FD1RV9USW1Y5 and CJHJBKNBK6L5 across all 9 identified CAGE codes (17038, 1B3A2, 3QEW9, 33QY3, 56AU8, 1C4G2, 1HUY4, 3APK3, 6BGV5), filtering specifically for Delivery Orders against GSA Schedules GS-35F-0138U, GS-35F-0533L, and GS-10F-044TA.
3. Trade Association Governance Verification:
   • Inspect IRS Form 990 filings (Part VII, Officers and Directors) for the Professional Services Council for tax years 2022, 2023, and 2024 to verify whether Horacio Rozanski or any other BAH executive held an unpublicized board position.
4. State-Level Capital Subsidies:
   • File a Maryland Public Information Act (PIA) request with the Maryland Department of Commerce regarding tax credits issued under the Enhanced Tax Credit for Federal Defense Contractors (2018) for BAH capital improvements at Annapolis Junction between 2020 and 2023 to ascertain state-level funding of its classified Innovation Center.
5. OTA Consortia Flow-Down Documentation:
   • Query DoD procurement registries and FPDS-NG for transactions citing OTA consortia management agreements (specifically NSTXL, C5, and DIU) cross-referenced against BAH CAGE codes to isolate follow-on production task orders between $100M and $500M awarded under Section 844 authorities.