Integrity Review

Integrity Review incorporates all of the steps in Paragon’s lower tier anti-terrorist financing screening service (ATFS and ATFS HR). This services expands diligence to address corruption, governance, and reputational risks that may affect a grantee’s credibility.

Integrity Review is the third tier of Paragon’s Four-Tier Due Diligence Framework. Escalation to IR is recommended when risks include corruption, fraud, organized crime, political exposure, material subcontractors or vendors, governance gaps, or elevated-risk geographies.

Screening at this level includes PEP checks and reputational adverse media across the entity, key persons, banks, and disclosed vendors/subcontractors. Control relationships are screened at the entity-name level against sanctions, PEP, and adverse media, with full reviews available under higher tiers if warranted. Governance and accountability policies are reviewed alongside procurement and conflict of interest policies, and geography risk ratings are applied. Declared intermediary banks are also screened for sanctions and adverse media to identify vulnerabilities in payment routes. This stage delivers a broad integrity review of the grantee and its ecosystem.