Anti-Terrorist Financing Screening

Anti-terrorist financing screening (ATFS) is the baseline safeguard for cross-border grantmaking. Terrorist networks exploit the same financial systems and nonprofit structures that legitimate charities use, so every international grant carries some risk of diversion, regulatory exposure, and reputational damage. Wherever a funder is based, screening against sanctions and terrorism lists is a standard control within a broader compliance program, reflected in guidance from bodies such as the Financial Action Task Force (FATF). Screening does not by itself establish compliance with any legal or regulatory obligation.

  • 14 years Serving global grantmakers
  • 100+ Countries, including higher-risk jurisdictions
  • 3,000+ Vetted nonprofits in the registry

Tier 1

ATFS Service

ATFS is Paragon’s baseline anti-terrorist financing screening service, and Tier 1 within the Four-Tier Framework. Designed for an international audience, ATFS combines rigorous sanctions and watchlist screening with identity verification and review of the registration and identity documents the organization provides, covering the entity, its leadership and controlling entities, and its declared financial institutions. Our process aligns with FATF standards and integrates official lists from OFAC, the United Nations, the European Union, the United Kingdom, and other major international authorities.

ATFS-HR (Tier 2) includes every step of the baseline ATFS service and adds the checks below.

What is includedTier 1ATFSThis serviceTier 2ATFS-HR
Identity and registration reviewRegistration documents and certified disclosures on leadership, ownership, control, and banks✓✓
Global sanctions and watchlist screeningOrganization, governing body, key persons, controlling parties, and declared banks, with every potential match resolved✓✓
OFAC country-based sanctions programsFor each reported country of activity, with applicable general licenses noted✓✓
Jurisdictional risk indicatorsOFAC program exposure, FATF listing, documented terrorist group presence, and Basel AML Index and Corruption Perceptions Index scores, recorded as escalation considerations✓✓
Added at Tier 2
National sanctions screeningCountry of primary registration, via Dow Jones RiskCenter–✓
Adverse media reviewTerrorism- and financial-crime-focused, organization level–✓
Bank-issued account status documentationReviewed where provided–✓
Policies and downstream partner oversightVendors, subcontractors, and subgrantees, where applicable–✓
Integrity and reputational escalation indicatorsAdverse media, political exposure, control by another organization, disclosed integrity matters, payment and cash-handling controls, and downstream partner oversight, flagged to inform the decision on escalating to Tier 3–✓

How ATFS Works

Information Collection

ATFS is an analyst-led service. Paragon engages directly with the grantee to obtain the required information and documentation, and reviews relevant public sources for completeness. The organization certifies its disclosures as accurate and supports them with registration certificates and other documentation, which together form the evidentiary basis for screening.

Who is screened

Governing bodyBoard members
Founders
Persons with operational authority
The organizationLegal and alternate names
Beneficial owners and controlling individuals
Controlling entities
Financial institutionsDeclared and routing banks

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 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 (e.g., certificate of registration, charter, or equivalent) confirming current legal status and consistency with the names to be screened.
  • Obtain a certified list of board members, founders, persons with operational authority, beneficial owners, controlling entities and controlling individuals, affiliated organizations, declared financial institutions, and locations of operation; affiliated organizations are recorded as disclosures and are not screened.
  • Obtain supporting documentation where the organization holds it, 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 and its alternate names, its persons with operational authority, governing body members, founders, beneficial owners, controlling individuals, disclosed controlling entities, and disclosed financial institutions and routing banks, against the global sanctions and terrorism-related watchlists available through the CSI WatchDOG Elite platform at the time of screening, including, at a minimum:
    • U.S. Office of Foreign Assets Control (OFAC) SDN and SSI lists
    • OFAC-related lists (FSE, CAPTA, NS-MBS, NS-CMIC, Non-SDN PLC, and the Department of State Cuba Restricted List)
    • European Union sanctions
    • United Nations Consolidated Sanctions List
    • UK Sanctions List (FCDO)
    • U.S. Terrorist Exclusion List
    • Law enforcement sources
    • FinCEN Section 311 special measures
  • Follow-Up and Match Resolution: Conduct follow-up analysis on all potential matches, contacting the organization and obtaining secondary information where necessary to confirm or resolve positive hits and any discrepancies. Record each resolution and its supporting evidence in the screening file, creating an auditable record of analyst actions and findings.

Deliverable: ATFS Report

Paragon provides the client with a written Anti-Terrorist Financing Screening (ATFS) Report.

What the ATFS Report contains

  1. Executive snapshot of key findings

  2. Watchlist screening table

    With match-resolution determinations

  3. Reported countries of activity

    Whether any OFAC country-based sanctions programs apply, with applicable OFAC general licenses noted for the client’s review

  4. Control relationships and beneficial ownership

  5. Escalation considerations

    Jurisdictional risk, control relationship, and grant structure indicators, recorded to support the client’s decision on whether ATFS-HR is appropriate

Sample report available on request›

How it fits

ATFS Within Paragon’s Four-Tier Framework

The Four-Tier Framework lets funders match the depth of due diligence to the risk identified during review. ATFS sets the baseline. Where elevated risk factors such as higher-risk geographies, complex ownership, or inconsistent disclosures appear, funders may escalate to Tier 2 for national-level sanctions and terrorism-focused adverse-media checks, to Tier 3 for governance, corruption, and reputational risks, or to Tier 4 for registry-verified ownership, litigation, and enforcement checks.

14 yearsServing global grantmakers

100+Countries, including higher-risk jurisdictions

3,000+Vetted nonprofits in the registry

Selected Clients

14 yearsServing global grantmakers

100+Countries, including higher-risk jurisdictions

3,000+Vetted nonprofits in the registry

The Rockefeller Foundation

Chicago Community Trust

Greater Houston Community Foundation

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

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