VALVe uses VAC2 (an internal solution).
It's far less effective than PunkBuster, and has been cracked/bypassed numerous times.
You can't really compare America's Army with this (or any other) game.
It has such a big cheat problem because people can make infinite accounts,
without loss of money (seeing how accounts are free).
In America's Army, all you have to do is create a new account, which will give you
a new GUID, thus bypassing your ban (excluding hardware bans, of course).
I (obviously) voted Yes.