Anti-Terrorist Financing Screening
Anti-terrorist financing screening (ATFS) 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), helps prevent violations that could lead to severe penalties under national sanctions regimes, 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, and Tier 1 within the Four-Tier Framework. 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 major international authorities.
Where indicators such as higher-risk geographies, government ownership or control, multi-jurisdictional operations, or other material risk factors are present, Paragon’s Higher Risk Anti-Terrorist Financing Screening service (ATFS-HR) is recommended. Jurisdictions with elevated corruption levels and weaker anti-money-laundering (AML) controls present increased exposure to diversion of funds, including potential misuse by terrorist entities. For corruption risk, Transparency International’s Corruption Perceptions Index (CPI) provides country-level scores, while the Basel AML Index offers a globally recognized composite rating for money-laundering and terrorist-financing risk. Grantees operating in countries ranking poorly on either index should undergo ATFS-HR screening.
Information Collection and Verification
ATFS is an analyst-led service in which Paragon engages directly with the grantee organization to obtain and verify required information and documentation, while also reviewing relevant public sources where available for completeness. Paragon obtains verified details on the organization’s legal and alternate names, addresses, and registration; jurisdiction of operation; leadership, founders, board members, controlling or affiliated entities; and declared financial institutions. It also captures information on ownership and governance, and any government or political affiliations. These verified inputs, supported by registration certificates and other documentation, form the evidentiary basis for sanctions and watchlist screening across all relevant jurisdictions.
ATFS Screening Steps
ATFS screening is a structured process used to establish organizational identity, evaluate sanctions and watchlist exposure, and compile the evidentiary record supporting responsible cross-border due diligence. It includes the following steps:
1. Identification and Source Verification
- Obtain and verify the organization’s legal and alternate names (in English and, where applicable, the language of origin), acronyms, and all known addresses in countries of operation or registration.
- Review the organization’s website and publicly available sources to identify any additional alternate names, acronyms, or addresses for screening.
- Secure official registration and identity documents confirming current legal status (e.g., certificate of registration, charter, or equivalent).
- Obtain a certified list of key personnel—board members, founders, senior management, controlling entities, affiliated organizations, declared financial institutions, and locations of operation—to ensure comprehensive coverage of all names subject to screening.
- Ensure all collected information is supported by verifiable documentation forming the evidentiary basis for sanctions and watchlist screening.
2. Sanctions and Watchlist Screening
- Global Watchlist Screening: Screen all collected names and entities— including the organization, its key personnel, and related entities—against major global sanctions and terrorism lists, including:
- Office of Foreign Assets Control (OFAC SDN and TEL lists)
- European Union (EU) Consolidated List
- United Kingdom (UK) Sanctions List
- United Nations Sanctions List (UNSL)
- Federal Bureau of Investigation (FBI) Most Wanted Terrorists and Terrorist Exclusion List
- Interpol Notices and Databases
- Follow-Up and Match Resolution: Conduct follow-up analysis on all potential matches, contacting the organization as needed to confirm or resolve positive hits and to ensure accurate screening results.
3. Documentation
- Confirm that the organization’s registration and identity documents are current and consistent with the names screened.
- Record all match resolutions and supporting evidence in the screening file, creating an auditable record of analyst actions and findings.
- Where additional clarification is required, obtain secondary information directly from the organization to verify accuracy and resolve potential discrepancies.
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 as provided by the organization. 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 Framework
ATFS forms Tier 1 of Paragon’s Four-Tier 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 Anti-Terrorist Financing Screening) 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.
View this service within the Four-Tier Framework ›
Paragon’s risk-based due diligence framework helps funders align vetting depth with risk.
Learn more >
Selected Clients
The Rockefeller Foundation
Greater Houston Community 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