Higher Risk Anti-Terrorist Financing Screening

ATFS-HR represents Tier 2 in Paragon’s Four-Tier Due Diligence Framework and includes all steps performed under ATFS (Tier 1), with additional measures for elevated-risk contexts. It adds national and local sanctions screening through Dow Jones RiskCenter, terrorism-focused adverse media screening, state-ownership checks, and a deeper review of control relationships and policies affecting downstream partners (vendors, subcontractors, and, where relevant, subgrantees). ATFS-HR is applied when indicators such as higher-risk geographies, government ownership or control, multi-jurisdictional operations, registration inconsistencies, special foreign-funding registrations, or higher-risk banking corridors are present. ATFS-HR organizes its checks across four analytical dimensions—core organization risk signals, financial channels, downstream partners, and monitoring—to ensure proportionate coverage of all potential exposure points.

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. For ATFS-HR, the information set also includes any available anti-terrorism policies, vendor/subcontractor (and, if relevant, subgrantee) selection and oversight policies, disclosures related to government ownership or control, payment-routing details, and clarifications needed to resolve local registry or multi-jurisdictional issues. The ATFS HR service includes the following anti-terrorist financing screening steps:

• Screen names and information against global watchlists (OFAC SDN, TEL, EU, UK, UNSL, FBI, Interpol) and an expanded set of national and local sanctions/exclusion lists via Dow Jones RiskCenter (see Annex A for illustrative sources).
• 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 globally and against local/national lists via Dow Jones RiskCenter.
• As needed, secure secondary information directly from the grantee to resolve any potential matches.
• Identify state ownership or government control using Dow Jones RiskCenter sources; document control relationships as disclosed or verified.
• Conduct terrorism-focused Adverse Media Screening (AMS) of the organization and declared banks using Dow Jones RiskCenter, helping identify early-warning indicators consistent with FATF guidance on enhanced due diligence.
• Review anti-terrorism and vendor/subcontractor (and, if relevant, subgrantee) selection and oversight policies to assess downstream controls.
• Screen declared banks against local/national lists; review payment-routing information to identify exposure via higher-risk corridors.
• Incorporate geographic risk triggers to flag operations or counterparties in high-risk regions or municipalities and support escalation decisions.
• Monitoring and ongoing grantee engagement follow the same procedures established in Tier 1, with escalations documented as needed in Tier 2.

Deliverable: ATFS-HR Report
Paragon provides a written ATFS-HR Report documenting all screening activities, matches, and resolutions, including results from global and local/national sanctions checks (Dow Jones RiskCenter), terrorism-focused adverse media screening, state-ownership review, bank and payment-routing checks, and policy reviews for anti-terrorism and downstream partner oversight. The report includes a detailed summary of findings, a “Review and Resolve” verification record, source documents, and confirmations of current registration or good standing, providing a defensible, audit-ready record for higher-risk engagements.