Due Diligence and Screening for Canadian Grantmakers
For registered charities making grants to non-qualified donees, Paragon’s services are organized around the low, medium and high risk levels in CRA guidance CG-032. The grantmaker assigns the risk level and selects the services; Paragon delivers a written report for each grantee, documenting the review for the grantmaker’s records. Screening covers Canada’s sanctions and terrorist designations alongside the international lists. The same services are available to corporate giving programs, non-profit funders and other Canadian grantmakers outside the charity framework.
What the screening covers
Paragon’s services contribute to the first of the guidance’s six accountability tools, research and review of the grantee. In the two core services, Paragon works with each grantee directly. Anti-Terrorist Financing Screening (Tier 1) collects information on the organization, leadership, governing body, beneficial owners and declared banks. Higher-Risk Anti-Terrorist Financing Screening (Tier 2) adds national sanctions lists for the country of registration, adverse media for terrorism-related and financial-crime exposure, a review of the grantee’s partner, vendor and subgrantee policies, and bank-issued account status documentation where provided. The Canadian designations screened include Criminal Code listed terrorist entities, the list under the Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism, Special Economic Measures Act sanctions and Justice for Victims of Corrupt Foreign Officials Act listings; the international lists include the United Nations, OFAC, UK and EU lists. Each report includes a Canadian sanctions section for the grantee’s country of registration and countries of activity. Politically Exposed Person Screening, Integrity Review and no-contact validation are available where the grantmaker requires them.
The full overview below pairs each CRA risk level with the services that can support it, and sets out what each service includes, the lists screened and the scope of Paragon’s role.
“The risk level will help determine whether the use of accountability tools will be limited, moderate, or extensive.”
Canada Revenue Agency,Registered charities making grants to non-qualified donees (CG-032)
Related
Paragon’s Four-Tier Framework helps funders align vetting depth with risk.
Tier 1: sanctions and watchlist screening of the grantee, its leadership, its controlling parties and its declared banks.
Tier 2: adds national sanctions screening for the grantee’s country of registration, adverse media, a review of the grantee’s partner oversight policies, and bank-issued account documentation.