Red Flags of Collusion 

You can help prevent collusion in procurement and grant awards — or detect collusion 

after an award has been made — by using this simple four-part MAPS analysis: 

M = MARKET

Who is in the market for this award? 

Find out how many vendors could complete for the award and which vendors are best 

positioned to perform the award. The award may be the target of collusion if: 

; There are few vendors in the market that offer the good or service. 

; A small group of major vendors controls a large share of the market. 

; The good or service is standardized, so that the determining factor in the 

award is price rather than other competitive factors (such as design, 

quality, or service).

A = APPLICATIONS

Are there similarities between vendor applications or proposals?

Closely examine the proposals or applications submitted by the competing vendors and 

look for similarities. The award may be the target of collusion if: 

; Two or more proposals contain similar handwriting, typos, or mathematical 

errors. 

; Two or more proposals are sent from the same mailing address, e-mail address, 

fax number, or overnight courier account number. 

; Two or more proposals reflect that last-minute changes (such as white-outs and 

cross-outs) were made to alter price quotes. 

; The document properties of two or more electronic proposals show that the 

proposals were created or edited by one vendor. 
P = PATTERNS

Have patterns developed among competing vendors? 

Review the outcome of prior awards for the same product or service to identify patterns 

over time. The award may be the target of collusion if: 

; Over a series of awards, competing vendors rotate as the award winner. 

; Over a series of awards, routine competing vendors win the same or similar 

amounts of work. 

; Over a series of awards, one vendor always wins, regardless of competition. 

; The vendor that wins the award subcontracts work to losing vendors or to 

vendors that withdrew their proposals or refused to submit proposals. 

; As compared with prior awards, a smaller number of vendors submit proposals 

for the current award. 

S = SUSPICIOUS BEHAVIOR

Have vendors demonstrated behavior that suggests that they worked together on the 

award?

Keep an eye out for suspicious behavior that indicates that vendors worked together 

rather than competed for the award. The award may be the target of collusion if: 

; A vendor submits a proposal for a procurement or grant award, and you know 

that the vendor lacks the ability to provide the goods or services requested. 

; A vendor brings multiple proposals to an in-person procurement or grant 

process or submits multiple proposals. 

; A vendor makes statements on the phone or by e-mail indicating advance 

knowledge of a competitor's prices or likelihood of winning the award. 

If you notice any combination of these red flags, you should report your concerns to the 

Antitrust Division. 

E-mail: antitrust.complaints.recovery@usdoj.gov 

Mail: Citizen Complaint Center 

 Antitrust Division 

 950 Pennsylvania Avenue, NW 

 Room 3322 

Washington, DC 20530 

Phone: 1-888-647-3258 (toll free in the U.S. and Canada) or 202-307-2040