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 included | Tier 1ATFSThis service | Tier 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
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
Executive snapshot of key findings
Watchlist screening table
With match-resolution determinations
Reported countries of activity
Whether any OFAC country-based sanctions programs apply, with applicable OFAC general licenses noted for the client’s review
Control relationships and beneficial ownership
Jurisdictional risk, control relationship, and grant structure indicators, recorded to support the client’s decision on whether ATFS-HR is appropriate
How it fits
ATFS Within Paragon’s Four-Tier Framework
- Tier 1Anti-Terrorist Financing Screening (ATFS)This service
- Tier 2Higher-Risk Anti-Terrorist Financing Screening (ATFS-HR)Available when findings warrant escalation
- Tier 3Integrity Review (IR)Available when findings warrant escalation
- Tier 4Integrity Due Diligence (IDD)Available when findings warrant escalation
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
Paragon’s Four-Tier Framework helps funders align vetting depth with risk.
When Baseline Screening Isn’t Enough ›
Understanding the escalation indicators recorded in every ATFS report and when higher-risk screening is warranted.
Learn more >
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
