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.

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 administrative review of the registration and identity documents the organization provides, covering the entity, its leadership and controlling entities, and its declared financial institutions. Paragon’s process is informed by FATF standards and integrates official lists from OFAC, the United Nations, the European Union, the United Kingdom, and other major international authorities. For comparison, the table below also shows the additional checks included in ATFS-HR (Tier 2).

What is included	Tier 1ATFSThis service	Tier 2ATFS-HR
Identity and registration reviewRegistration documents, the public registry listing where one exists, and certified disclosures on leadership, ownership, control, and banks	✓	✓
Global sanctions and watchlist screeningOrganization, governing body, key persons, controlling parties, and declared banks	✓	✓
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	–	✓
Adverse media reviewOrganization level: terrorism, sanctions exposure, financial crime, corruption and misuse of funds	–	✓
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 carried out by Paragon’s vetting team. 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. Paragon reviews these documents for internal consistency. It does not authenticate them with the issuing authority or institution.

An organization can clear screening under its own name while a person who directs it, an entity that owns or controls it, or a bank that handles its funds appears on a sanctions or terrorism list. That is why ATFS screens the organization and each of these parties, as shown below. Name screening is only one part of the service, which also covers the identity and registration review, country-based sanctions programs and jurisdictional risk indicators set out above.

Who is screened against watchlists

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. Names, Disclosures and Documents

Obtain the organization’s legal and alternate names (in English and, where applicable, the language of origin), acronyms, and each address it discloses in its country of primary registration or its reported countries of activity.
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:
United Nations: United Nations Consolidated Sanctions List
European Union: European Union sanctions
United Kingdom: UK Sanctions List (FCDO)
United States: U.S. Office of Foreign Assets Control (OFAC) SDN and SSI listsOFAC-related lists (FSE, CAPTA, NS-MBS, NS-CMIC, Non-SDN PLC, and the Department of State Cuba Restricted List)U.S. Terrorist Exclusion ListFinCEN Section 311 special measures
Law enforcement: Federal Bureau of Investigation (FBI)Interpol
Canada: For grantmakers in Canada, screening also covers the Criminal Code list of terrorist entities, the list under the Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism, and listings under the Special Economic Measures Act, the Justice for Victims of Corrupt Foreign Officials Act and the Freezing Assets of Corrupt Foreign Officials Act.
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 a complete record of the actions taken and findings.

Deliverable: ATFS Report

Paragon provides the client with a written Anti-Terrorist Financing Screening (ATFS) Report. The report covers the single legal entity named in the engagement. Any other legal entity, including one in another country that shares the organization’s name or brand, is a separate screening subject and is covered only if separately engaged.

Contents

What the ATFS Report contains

01Executive snapshot of key findings

Watchlist results, any reported control by or affiliation with a government or another organization, and any escalation indicators relevant to ATFS-HR, summarized on the first page

02Watchlist screening table

With match-resolution determinations

03Reported countries of activity

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

04Control relationships and beneficial ownership

Control by other organizations or by governmental entities, and beneficial owners as disclosed by the organization

05Escalation considerations

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›

For a grant payment that also needs grant agreement signatures, wire verification or a foreign country requirements check, Paragon pairs ATFS with these safeguards in its PLUS Service.

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 checks and adverse-media checks for terrorist financing risk, to Tier 3 for governance, corruption, and reputational risks, or to Tier 4 for registry-verified ownership, litigation, and enforcement checks.

Tier 1ATFSAnti-Terrorist Financing ScreeningThis service

Tier 2ATFS-HRHigher-Risk Anti-Terrorist Financing ScreeningAvailable on request Tier 3IRIntegrity ReviewAvailable on request Tier 4IDDIntegrity Due DiligenceAvailable on request

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Four-Tier Framework ›

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.

Regional Guidance

How Paragon conducts anti-terrorist financing screening for grantmakers based in Canada and the European Union, including the Canadian and EU sanctions and terrorist lists screened.

Canada ›European Union ›