Higher Risk Anti-Terrorist Financing Screening

ATFS-HR is an analyst-led process carried out through a defined sequence of screening steps designed to support proportionate, risk-based assessment in higher-risk grantmaking contexts. Paragon works directly with the grantee organization to obtain and verify core identifying, governance, and financial information, supported by appropriate documentation and supplemented by relevant public-source review where available. These verified inputs provide the evidentiary basis for sanctions, watchlist, adverse media, and contextual risk screening across applicable jurisdictions, ensuring that screening outcomes are grounded in confirmed organizational information rather than unverified representations. Where relevant, Paragon also reviews available policies related to anti-terrorism compliance and oversight of downstream partners to inform assessment of internal controls. The steps below describe how this verified information is applied in a structured manner to identify, assess, and document potential exposure to terrorist financing and related financial-crime risk:

1. Identification and Source Verification

• Obtain and verify the grantee’s legal and alternate names (in English and the language of origin), acronyms, and all known addresses in countries of registration and operation.
• Confirm the jurisdiction of registration and principal place of operation to establish the applicable regulatory and legal framework.
• Review the grantee’s website and public sources to identify additional alternate names, addresses, or operating locations for screening.
• Secure official registration and identity documents confirming current legal status (e.g., certificate of registration, charter, or equivalent).
• Obtain a certified list of key personnel—board members, founders, senior management, controlling entities, affiliated organizations, financial institutions, and geographic locations of operation—to ensure comprehensive coverage of all names subject to screening.
• Document the organization’s ownership and governance structure, including any parent, subsidiary, or affiliated entities, to determine ultimate control and accountability.
• Identify any government, political, or state-linked affiliations or ownership that could indicate elevated exposure under FATF’s definition of politically exposed persons (PEPs) or state-owned entities.
• Obtain copies of any available anti-terrorism, compliance, or sanctions policies, as well as partner, vendor, subcontractor, or subgrantee oversight policies, where applicable, to assess internal downstream controls.
• Confirm declared banking institutions and account details, noting any information relevant to the later verification of banking good standing (see Step 6).
• Ensure all collected information is supported by verifiable documentation forming the evidentiary basis for sanctions, watchlist, and adverse-media screening.

2. Sanctions and Watchlist Screening

• Global Watchlist Screening: All collected names and entities, including the organization, key personnel, and related entities, are screened against major global sanctions and terrorism lists maintained by the U.S. Office of Foreign Assets Control (OFAC SDN), Terrorist Exclusion List (TEL), European Union (EU), United Kingdom (UK), United Nations Sanctions List (UNSL), Federal Bureau of Investigation (FBI), and Interpol. Screening is conducted via CSI WatchDog.
• National Screening: The organization’s legal and alternate names; leadership, board, founders, and key staff; and other relevant identifiers are screened against an expanded set of national sanctions and exclusion lists via Dow Jones RiskCenter. These lists capture entities and individuals designated by in-country regulators, including central banks, financial intelligence units (FIUs), and ministries of interior or finance (see “Why National Sanctions Screening Matters” and Annex A for sources).
• Ownership and Control Analysis: Paragon reviews the organization’s disclosures to identify any indicators of state ownership, government affiliation, or political control. Any disclosed control relationships, such as ownership by, or affiliation with, governmental bodies, political parties, or state-linked enterprises, are recorded and documented as part of the screening file. Where clarification is needed, Paragon follows up directly with the organization to confirm the nature and extent of control.
• Bank and Intermediary Screening: Declared banks and intermediary financial institutions are screened against both global and national sanctions lists to assess the integrity of payment channels and detect any exposure to sanctioned or high-risk institutions.

3. Adverse Media and Contextual Risk Analysis

• Conduct terrorism-focused Adverse Media Screening (AMS) on the organization, its principals, and declared banks using Dow Jones RiskCenter, to identify early-warning indicators of terrorism financing or financial-crime exposure consistent with Financial Action Task Force (FATF) enhanced due diligence guidance.

4. Follow-Up Verification and Match Resolution

• Perform secondary verification directly with the grantee when screening identifies potential matches, obtaining clarifying documentation or statements as needed.

5. Policy and Downstream Controls Review

• Review the organization’s anti-terrorism and vendor, subcontractor, and subgrantee oversight policies (where applicable) to evaluate downstream controls and alignment with FATF recommendations.

6. Verification of Banking Good Standing

• Paragon verifies, based on information provided by the organization, that the organization’s primary banking institution and active accounts are in good standing, with no indications of account freezes, regulatory restrictions, or adverse actions by the bank. The purpose of this verification is to confirm that the grantee’s accounts have not been flagged or restricted for suspected illegal activity, money laundering, or terrorist financing, and that the organization maintains an active, reputable banking relationship with a regulated financial institution. Documentation or confirmation of banking status is obtained directly from the organization and retained in the screening record.

7. Geographic Risk Triggers

• Paragon reviews the countries in which the grantee operates to determine whether any would likely be considered higher risk under widely recognized international standards, including Financial Action Task Force listings, Basel AML Index scores, Corruption Perceptions Index rankings, and OFAC country-based sanctions programs. Countries that fall into higher-risk categories under these sources are noted and may guide escalation decisions within Paragon’s Four-Tier Framework. Any geographic risk observation relates only to the jurisdiction and is not an assessment of the organization itself.