Expenditure Responsibility PLUS

 

“Working with Paragon reduces the burden on our team and gives us the confidence that foreign grantees have been thoroughly vetted. We appreciate Paragon’s excellent customer service, knowledge of international grantmaking compliance, and fast turn-around.”

— Krystle Folse, Director of Donor Services, Greater Houston Community Foundation

 
 
 

Through Expenditure Responsibility, a grantmaker carries out a series of steps in order to make sure that funds are spent according to a specific charitable purpose. Expenditure Responsibility is the favored approach when making project-specific grants, or grants to organizations that would not likely qualify under Equivalency Determination.

In addition to Expenditure Responsibility steps, Expenditure Responsibility PLUS includes watch list screening (SDN search, etc.) at the Silver Vetting level and review of foreign country requirements affecting the grantmaker and grantee. We handle all communications with the foreign grantee, review required documents, secure grantee signatures, obtain wire transfer information, and confirm receipt of funds.

Our team manages the following steps for your family foundation, corporate foundation, or donor advised fund, from pre-grant inquiry to closeout:

 

New: Vetting Database

An organization appearing in the Paragon vetting database may be eligible for expedited or discounted vetting.

 
 

1. Pre-Grant Inquiry

  • Obtain and review key organizational documents from the grantee

  • Review the grantee's project narrative and budget

  • Collect information, as applicable, on:

    • capital expenditures and endowments

    • re-granting

    • activities related to lobbying and electioneering

    • scholarships and prizes

    • grants for food, shelter, and aid to the poor

 
 

2. Review of Foreign Country Requirements

  • Review regulations in the foreign country affecting the grantee and the grantmaker, and verify compliance. Alert client to any foreign country restrictions on the operations of civil society organizations that might be of particular concern.

 
 

3. Anti-Terrorist Financing Screening

  • Conduct anti-terrorism financing screening (SDN search, etc.) at the Silver Vetting level

  • Review OFAC Sanctions Programs for the countries in which the grantee is operating

  • Repeat screening as needed

 
 

4. Grant Agreement

  • Obtain grantee signatures on the grant agreement and any related documents

 
 

5. Wire Transfer Information & Receipt of Funds

  • Secure the grantee’s international wire transfer information

  • Confirm grantee receipt of funds

 

6. Reporting

  • Prepare the grant-specific reporting template

  • Adapt the template for custom reporting needs

  • Enter reporting deadlines into our system and schedule reminders

  • Collect report(s) from the grantee

  • Review report(s) and request grantee revisions as needed

 

7. Closeout

  • Conduct our final reporting review in strict accordance with Expenditure Responsibility guidelines

 
 

Selected Clients

The Rockefeller Foundation

The San Francisco Foundation

Chicago Community Trust

Greater Kansas City Community Foundation

Marin Community Foundation

RSF Social Finance

Douglas B. Marshall, Jr. Family Foundation

Rodan + Fields Prescription for Change Foundation

Whittier Trust

Communities Foundation of Texas