Anti-Terrorist Financing Screening
Anti-Terrorist Financing Screening (ATFS)
Anti-terrorist financing (ATF) screening represents the essential baseline safeguard for all cross-border grantmaking. In an interconnected world where terrorist networks exploit the same financial systems used by legitimate charitable organizations, every international grant carries inherent risks of fund diversion, regulatory violations, and reputational damage. The global reach of terrorism financing—driven by increasingly sophisticated methods spanning multiple jurisdictions, misuse of nonprofit structures, and abuse of conventional banking systems—makes comprehensive screening a critical first line of defense for grantmakers worldwide.
Whether a foundation operates from the United States, Europe, Australia, or any other jurisdiction, implementing robust ATF screening protocols ensures compliance with evolving international standards set by bodies such as the Financial Action Task Force (FATF), protects against the severe penalties associated with inadvertent fund diversion, and preserves the integrity essential to effective philanthropy. ATF screening thus forms the cornerstone of responsible international grantmaking, enabling organizations to pursue their charitable missions confidently while safeguarding against the exploitation of philanthropic resources by terrorist networks that continuously adapt and evolve across global regions through increasingly complex financial channels.
ATFS Service
ATFS is Paragon’s baseline anti-terrorist financing screening service. ATFS provides global grantmakers with a trusted first line of defense against the diversion of charitable funds. Designed for an international audience, ATFS combines rigorous sanctions and watchlist screening with identity verification and documentary validation across multiple jurisdictions, covering entities, leadership, and affiliated institutions. Our process aligns with global standards set by the Financial Action Task Force (FATF) and integrates official lists from OFAC, the United Nations, the European Union, the United Kingdom, and other regulatory bodies worldwide.
Information Collection and Verification
To initiate screening, Paragon obtains key organizational data directly from the grantee through the Organization Information Form. The form collects verified details on the organization’s legal name and registration, jurisdiction of operation, leadership, founders, board members, controlling or affiliated entities, and financial institutions. It also captures information on ownership and governance, any government or political affiliations, and special registration requirements for receiving foreign funds. These verified inputs—supported by registration certificates and other documentation—form the evidentiary basis for sanctions and watchlist screening across all relevant jurisdictions. This service includes the following anti-terrorist financing screening steps:
- Screen names and information provided by client against watch lists (OFAC SDN, TEL, EU, UK, UNSL, FBI, & Interpol lists).
- Conduct follow-up analysis on all watch list matches.
- Obtain from the grantee and screen: the grantee’s legal name in English and language of origin, alternative names and acronyms, and current addresses in country(ies) of operations or residence.
- Screen any alternate names and addresses for the grantee that can be identified on the grantee’s website.
- Obtain from the grantee documents confirming its identity and current registration (e.g., registered association).
- Obtain from the grantee a certified list of current key staff, board members, founders, controlling entities, financial institutions, and locations of operations; screen against OFAC SDN, TEL, EU, UNSL, UK, FBI, and Interpol.
- As needed, secure secondary information directly from the grantee to resolve any potential matches.
Deliverable: ATFS Report
Paragon provides the client with a written Anti-Terrorist Financing Screening (ATFS) Report documenting the results of comprehensive watchlist screening performed through the CSI WatchDOG Elite regulatory compliance platform. The report confirms whether the grantee, its principals, and related entities appear on OFAC, UN, EU, UK, FBI, and Interpol sanctions or terrorist exclusion lists, and whether any OFAC country-based sanctions programs apply. Each report includes a detailed summary of findings, a “Review and Resolve” verification record, source documents provided by the grantee, and proof of current registration or good standing. This deliverable establishes a verifiable record of screening and match resolution, supporting the client’s sanctions compliance documentation and broader risk-based due diligence file.
The ATFS Report forms the foundational component of Paragon’s broader risk-based due diligence model, described below.
ATFS Within Paragon’s Four-Tier Due Diligence Framework
ATFS forms Tier 1 of Paragon’s Four-Tier Due Diligence Framework, which provides a scalable and risk-proportionate model for cross-border grantmaking. The framework enables funders to apply due diligence that matches the level of risk identified during review. Tier 1 establishes the baseline through sanctions and terrorism screening of the grantee, its principals, and declared banks. When elevated risk factors such as higher-risk geographies, complex ownership, or inconsistent disclosures are identified, funders may escalate to Tier 2 (Higher-Risk ATFS) for additional national-level sanctions and terrorism-focused adverse-media checks. Tier 3 (Integrity Review) expands to include governance, corruption, and reputational risks, while Tier 4 (Integrity Due Diligence) applies registry-verified ownership, litigation, and enforcement checks for complex or high-risk cases. This tiered approach provides a clear structure for right-sizing due diligence across diverse portfolios. It supports consistency, efficiency, and alignment with FATF, OFAC, IRS, and comparable global standards.
Proven Track Record
Founded in 2012, Paragon has facilitated the vetting of thousands of grantees across more than 100 countries, including higher-risk jurisdictions identified by FATF, the OECD, and Transparency International. Our analyst-led process delivers practical cross-border due diligence and risk screening that evaluates mission alignment, governance, financial controls, sanctions and watchlist exposure, and country risk to help protect funder reputation. We provide structured, defensible documentation to support board oversight and strengthen cross-border giving.
Selected Clients
Greater Houston Community Foundation
The Rockefeller Foundation
Chicago Community Trust
Zoetis Foundation
Greater Kansas City Community Foundation
Marin Community Foundation
Douglas B. Marshall, Jr. Family Foundation
Rodan + Fields Prescription for Change Foundation
Whittier Trust
Communities Foundation of Texas