Equivalency Determination PLUS
Available in both standard and higher-risk service levels.
An Equivalency Determination (ED) is a grantmaker’s good faith determination, based on written advice from a qualified tax practitioner, that a non-U.S. organization is the equivalent of a U.S. public charity under Internal Revenue Code §§501(c)(3) and 509(a). With a valid ED, U.S. private foundations and donor-advised funds can make grants to that organization without exercising Expenditure Responsibility (ER). This allows them to fund global partners with confidence and speed.
- Regulatory assurance: EDs prepared to IRS Rev. Proc. 2017-53 standards provide an accepted alternative to ER.
- Flexibility: Enables general support and capital grants without ER oversight and reporting.
- DAF-friendly: DAF sponsors commonly rely on EDs to extend the same compliance protections to donor-advised grants.
- Faster access to partners: Using grantees with current EDs (including from reputable repositories) streamlines approvals.
Compliance support
The ED PLUS Service
ED PLUS comprises two service components:
Issued by an independent SEDP
The Equivalency Determination (ED) itself is issued by a Supported ED Provider (SEDP), an independent qualified tax practitioner. Paragon facilitates the process as the SEDP’s authorized agent for document collection, client and grantee communications, delivery of the ED, and collection of SEDP fees.
Additional safeguards
PLUS services deliver a targeted set of safeguards, including anti-terrorist financing screening, an updated review of basic foreign country requirements and, on request, facilitation of grant agreement signatures and verbal verification of wire details. By combining these steps into one service, PLUS supports consistent oversight, reduces the risk of fraud or diversion, and helps keep the grant file complete and well organized.
PLUS Service Components
Anti-Terrorist Financing Screening (ATFS) and the Basic Foreign Country Requirements Review are part of every ED PLUS engagement. Grant Agreement Signatures and Communications, and Wire Information and Confirmation of Receipt, are included in the service and provided on request.
Anti-Terrorist Financing Screening (ATFS)
Standard ED PLUS includes ATFS, Paragon’s baseline anti-terrorist financing screening service and Tier 1 of the Four-Tier Framework. Paragon manages all communications with the foreign grantee; collects and reviews core organizational documents; secures documentation of current legal registration status; and obtains either a certified list of persons with operational authority, board members, founders, beneficial owners, controlling entities and controlling individuals, and financial institutions, or formal confirmation that no changes have occurred. Paragon verifies updates to banking relationships, screens all relevant names and entities against U.S. and international sanctions and watchlists (including OFAC, UN, EU, UK, FBI, and Interpol), conducts follow-up analysis on potential matches, secures additional information from the grantee as needed, and generates a written screening report with full supporting documentation for the grant file. ED PLUS HR also includes Paragon’s enhanced anti-terrorist financing screening service (ATFS-HR). The screening included in ED PLUS covers the first grant payment; screening for later payments is engaged separately, through Paragon’s PLUS Service.
Why
Anti-terrorist financing screening is essential in cross-border grantmaking to reduce the risk that charitable funds are diverted to organizations or individuals associated with terrorism, money laundering, or other sanctioned activities. Risks may arise at any time due to changes in leadership, board composition, controlling entities, banking relationships, or registration status. Global watchlists (OFAC, UN, EU, UK, FBI, Interpol, and others) are continually updated. By verifying updates, confirming no changes, and re-screening the grantee before each disbursement, ATFS reduces the risk of inadvertently transferring funds to a sanctioned party and provides clear, documented support for compliance reviews.
Grant Agreement Signatures and Communications
Coordinating execution of the grant agreement by the grantee and client representatives through a secure e-signature platform, while facilitating communications between the parties to address any questions that may arise regarding the agreement. This process helps ensure that signatures are secure, time-stamped, and verifiable, creating a clear record for compliance and audit purposes. This service expressly excludes any legal review or analysis of the grant agreement.
Why
A signed agreement allows the grantor to reaffirm protective language around the charitable use of funds, compliance with anti-terrorist financing and sanctions laws, and adherence to reporting obligations. By requiring grantee and client signatures for each installment, the agreement provides that funds are disbursed under updated terms, protecting the grantor against misuse, diversion, or reputational risk while aligning with compliance expectations.
Wire Information and Confirmation of Receipt
This service includes the following steps:
- Securing wire information via secure e-signature platform
- Verbal verification of wire details
- Confirming receipt of funds by the grantee
Paragon compiles these steps into a report, creating a clear record that the payment was authorized, transmitted, and received as intended.
Why
Reconfirming and verifying wire details prior to each payment helps prevent costly errors and fraud, such as misdirected or spoofed wires, and ensures funds are documented as received as intended. By securing wire instructions in writing, verbally confirming no changes, and obtaining confirmation of receipt from the grantee, the client reduces diversion risk and keeps a clear record of each payment for compliance reviews.
Basic Foreign Country Requirements Review
This is a three-step review: (i) check the ICNL Civic Freedom Monitor for the relevant country; (ii) review the Council on Foundations (COF) Country Note; and (iii) request that the grantee identify which requirements apply when receiving foreign funding. Because these rules can change between payments, the review reconfirms applicable obligations each time. Information is included only if published by ICNL or COF. For countries not covered by these sources, clients may request Paragon’s Enhanced Foreign Country Requirements Review (EFCR). This review is informational only and does not constitute legal advice.
Why
Many jurisdictions impose registration, reporting, or approval requirements on nonprofits receiving foreign funding, and in some cases on U.S. grantmakers as well. Because these rules can change quickly, reviewing them before each disbursement provides an important safeguard. Noncompliance may delay transfers, expose the grantee to penalties, or risk suspension of operations. By consulting authoritative sources (ICNL, COF) and confirming requirements with the grantee, this review provides current reference points on restrictions that may affect a grant’s legality or safety, helping protect both funder and grantee.
Documentation Provided
At the close of each ED PLUS engagement, the client receives the following documentation for its grant file:
Due diligence and compliance
ED Written Advice
With supporting records, provided by the Supported ED Provider (SEDP)
ATFS Report
Anti-Terrorist Financing Screening (ATFS) report with screening logs and exhibits (standard service level)
ATFS-HR Report
Higher-Risk Anti-Terrorist Financing Screening (ATFS-HR) report, provided when the Higher-Risk service level is requested
ED PLUS HR
Foreign Country Requirements Summary
With supporting evidence
Grant execution
Grant Agreement E-Signatures
Secure e-signature facilitation of grant agreement signatures
If requested
Wire Verification Record
Wire instructions secured in writing, a record of the verbal verification of wire details, and confirmation of receipt
If requested
New, renewed, or reissued
ED PLUS by ED Status
ED PLUS adapts to where the grantee’s ED stands. The PLUS safeguards apply in each case; the ED steps and the fee vary with the ED’s status. Before a new ED is commissioned, Paragon can check a list of grantees against the repository and identify which hold an active ED available for reissue, which hold an ED that has lapsed, and which are not in the repository. There is no fee for this check.
New ED
When the grantee has no ED, or none that can be issued to you, Paragon facilitates a new ED through a Supported ED Provider (SEDP), as described above.
ED Recertification
When the grantee’s ED is expiring or has expired, the original issuing SEDP renews it, with Paragon coordinating updates and providing the same PLUS safeguards described above.
Repository ED
When the grantee holds an active, unexpired ED in the issuing SEDP’s repository, that same SEDP can newly issue it to you as a different requesting grantmaker. Paragon coordinates the reissue, performs an updated Anti-Terrorist Financing Screening (ATFS), and contacts the grantee directly to confirm that no changes to legal status, governance documents, or other key facts have occurred; where needed, Paragon obtains updated information and supporting documents. If the grantee’s legal status or governance documents have changed significantly, the SEDP may require a new ED or an ED recertification instead.
Higher-Risk Screening Option
For grants involving larger award amounts, higher-risk geographies, government-linked entities, or other elevated risk indicators, Paragon offers an enhanced service level: Equivalency Determination PLUS Higher-Risk (ED PLUS HR). This service integrates Paragon’s Higher-Risk Anti-Terrorist Financing Screening (ATFS-HR), a Tier 2 procedure within the Four-Tier Framework, into the standard ED PLUS process. ATFS-HR adds national sanctions screening via Dow Jones RiskCenter, adverse media searches covering terrorism, sanctions exposure, financial crime, corruption and misuse of funds, review of bank-issued account status documentation, and assessment of ownership, control, and government or political affiliations, alongside review of the grantee’s anti-terrorism and downstream-partner oversight policies.
Where ED PLUS sits in the Four-Tier Framework
Timeline and Delivery
Paragon prioritizes efficiency while maintaining excellence, accuracy, and documentation integrity in facilitating the delivery of Equivalency Determination (ED) projects. Upon receipt of all requested documentation and information from the grantee, ED projects are generally completed within two weeks, depending on SEDP follow-up and grantee responsiveness. Timelines may vary if translation, additional verification, or further coordination is required. Paragon provides clients with status updates at each stage, from document collection through delivery of the final ED package, to ensure transparency and predictable completion.
Rush Order Option
When a grant deadline requires it, clients may elect rush handling for an individual ED PLUS project. Rush handling accelerates the whole project, including collection of the grantee’s documentation, which is usually the longest stage. Paragon sets a firm deadline with the grantee at the outset, increases check-ins, offers video calls where language or capacity barriers exist, keeps the project at the top of its queue, and reviews it internally twice a week. Grantee responsiveness remains outside Paragon’s control, and rush availability depends on current workload and is limited during the holiday season.
Limitations
Paragon Philanthropy is not a law firm and does not provide legal advice; its services are administrative, risk-screening, and facilitative only, and EDs are issued by independent SEDPs.
Related
How the two approaches to grants for non-U.S. organizations compare.
Paragon’s Four-Tier Framework helps funders align vetting depth with risk.
“Paragon Philanthropy was a wonderful partner in assisting Omaha Community Foundation with an Equivalency Determination on a nonprofit in India. They were thorough in facilitating the ED, timely, and always kept us up-to-date on our progress. We had complete confidence in the final product we received and were able to provide for a donor.”
Hillary Nather-Detisch
Director of Donor Accounts
Omaha Community Foundation
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
