Higher-Risk Anti-Terrorist Financing Screening

Higher-Risk Anti-Terrorist Financing Screening (ATFS-HR) represents Tier 2 within Paragon’s Four-Tier Framework and is applied when baseline Anti-Terrorist Financing Screening is insufficient to address elevated risk indicators, or when a funder’s policy calls for it. ATFS-HR is appropriate for larger-scale awards or for grantmaking contexts characterized by factors such as higher-risk geographies, government ownership or control, multi-jurisdictional operations, or other material indicators that increase exposure to terrorist financing or related financial-crime risk.

When to consider ATFS-HR

Risk signals that call for a closer look

The ten indicators below are the circumstances that most often lead funders to choose ATFS-HR. Some describe where the grantee operates; others describe the grantee and the grant itself. Each points to exposure that baseline watchlist screening cannot surface on its own, which is why ATFS-HR adds national sanctions screening, terrorism-focused adverse media screening, and review of bank-issued account status documentation. No single indicator is decisive: escalation is usually warranted when several coincide or one presents acutely, and the decision rests with the funder.

Where the grantee operates

Country-level sanctions

A grantee can clear every watchlist and still operate in a country that is itself under comprehensive or targeted sanctions.

FATF grey or black list

A listing means the country has acknowledged gaps in its ability to detect and stop illicit financial flows.

Terrorist group presence

Designated terrorist organizations are documented as active in the country. This is a fact about the environment, not a finding about the grantee.

Basel AML Index score

A higher score signals greater systemic exposure to money laundering and terrorist financing.

Corruption Perceptions Index

A lower score points to weaker institutional controls, which make funds harder to trace through local intermediaries.

The grantee and the grant

Large or complex grant

More money and more moving parts create more handoff points where funds can be diverted.

Regranting or sub-awards

Screening the primary grantee does not reach the downstream recipients it funds.

First-time relationship

With no track record or prior reports to draw on, more rests on the screening itself.

Outside ownership or control

When a government body or another organization owns or controls the grantee, the parties behind the grant extend beyond the organization itself.

Multi-jurisdictional operations

Each additional country adds its own sanctions exposure and oversight environment.

When Baseline Screening Isn’t Enough ›

Tier 2

ATFS-HR Service

ATFS-HR includes every step of the baseline Anti-Terrorist Financing Screening (ATFS) service and adds the checks below.

What is included	Tier 1ATFS	Tier 2ATFS-HRThis service
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-HR Works

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-HR screens the organization and each of these parties, as shown below. Name screening is only one part of the service, which also covers the jurisdictional risk indicators, adverse media, banking documentation, policies and downstream partner oversight, and integrity 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-HR is carried out by Paragon’s vetting team through the defined sequence of steps below. Paragon works directly with the grantee to obtain its identifying and governance information and supporting documentation, certified as accurate by the organization and supplemented by public sources where available. Paragon reviews these documents for internal consistency. It does not authenticate them with the issuing authority or institution.

1. Names, Disclosures and Documents

Obtain the grantee’s legal and alternate names (in English and the language of origin), acronyms, and each address it discloses in its country of primary registration or its reported countries of activity.
Record the country of primary registration and the reported countries of activity as stated by the organization.
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 (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, financial institutions, and geographic locations of operation; affiliated organizations are recorded as disclosures and are not screened.
Document the organization’s ownership and governance structure, including any parent, subsidiary, or affiliated entities, as disclosed by the organization.
Record declared banking institutions and account details.
Obtain supporting documentation where the organization holds it, 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 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, are screened against the global sanctions and terrorism-related watchlists available 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: OFAC SDN and SSIOFAC-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
Screening is conducted via CSI WatchDOG Elite.
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.
National Screening: The same names screened against the global lists are screened against the national sanctions and exclusion lists maintained for the organization’s country of primary registration (see “National Sanctions Screening” below). Screening is conducted via Dow Jones RiskCenter.
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 in the screening file. Where clarification is needed, Paragon follows up directly with the organization to confirm the nature and extent of control. This analysis is disclosure-based. Politically exposed person (PEP) database screening is not part of ATFS-HR and is available through Paragon’s PEP Screening service.
Bank and Intermediary Screening: Declared banks and intermediary financial institutions are screened against both global and national sanctions lists, and any designation identified is recorded.

3. Adverse Media and Contextual Risk Analysis

Conduct Adverse Media Screening (AMS) on the organization’s name and any other names it uses via Dow Jones RiskCenter, covering terrorism and four areas that can signal terrorist financing risk: sanctions exposure, financial crime, corruption and misuse of funds, consistent with Financial Action Task Force (FATF) enhanced due diligence guidance.

4. Follow-Up Verification 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.

5. Policy and Downstream Controls Review

Obtain and review the organization’s anti-terrorism, compliance, or sanctions policies and its vendor, subcontractor, and subgrantee oversight policies (where applicable), and record whether the documents provided support the organization’s stated positions. This review is disclosure-based: vendors, subcontractors, subgrantees and implementing partners are not screened by name.

6. Bank-Issued Account Status Documentation

Paragon requests bank-issued documentation of the organization’s account status from the organization and records what it states about the primary banking institution and active accounts, including any account freezes, regulatory restrictions, or adverse actions by the bank, and any indication that accounts have been flagged or restricted for suspected illegal activity, money laundering, or terrorist financing. Paragon does not itself confirm that an account is in good standing.

7. Geographic Risk Triggers

Paragon records, for the country of primary registration and each reported country of activity, the published indicators 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. Paragon reports published figures and does not assign independent risk thresholds or classifications; escalation decisions rest with the client. Any geographic risk observation relates only to the jurisdiction and is not an assessment of the organization itself.

Deliverable: ATFS-HR Report

Paragon provides a formal ATFS-HR Report, a complete and traceable record of the screening, with the supporting documents attached. 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-HR Report contains

01Executive snapshot

Every result on one page, from watchlist matches and bank screening to the policies provided and any escalation considerations.

02Watchlist screening with match resolution

Global watchlists, plus national sanctions lists for the country of primary registration, covering the organization, its governing body, key persons, controlling parties, and banks. Every potential match is shown with the reason it was resolved.

03Country sanctions exposure

OFAC country-based sanctions programs for each reported country of activity, with applicable OFAC general licenses identified for the client’s review.

04Adverse media review

Organization-level adverse media review covering terrorism, sanctions exposure, financial crime, corruption and misuse of funds.

05Bank account status

The bank-issued account status documentation the organization provided.

06Policies and downstream controls

The organization’s answers on its anti-terrorism and anti-money laundering policies, partner and vendor oversight, financial controls, and reporting channels, each checked for a supporting provision in the documents it provided. This is disclosure-based; Paragon does not assess legal adequacy.

07Escalation considerations for Tier 3

Jurisdictional indicators for each country (FATF listing, documented terrorist group presence, Basel AML Index and Corruption Perceptions Index scores), integrity indicators, and grant structure considerations, consolidated to support the client’s decision.

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-HR with these safeguards in PLUS Higher-Risk.

ATFS-HR 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-HR builds on the ATFS baseline. Where its findings point to integrity or reputational concerns, funders may escalate 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 ScreeningIncluded in every ATFS-HR

Tier 2ATFS-HRHigher-Risk Anti-Terrorist Financing ScreeningThis service

Tier 3IRIntegrity ReviewAvailable on request Tier 4IDDIntegrity Due DiligenceAvailable on request

Why National Sanctions Screening?

National sanctions screening is one of the core components of ATFS-HR. While global sanctions lists such as those maintained by the U.S. Office of Foreign Assets Control (OFAC), the United Nations, the European Union, and the UK Foreign, Commonwealth & Development Office (FCDO) provide essential baseline coverage, they often omit entities or individuals subject to enforcement by national or in-country authorities. National regulators, including central banks, financial intelligence units (FIUs), and ministries of interior or finance, frequently issue their own designations tied to domestic counterterrorism, corruption, or money-laundering investigations. These actions may not trigger inclusion on global lists but nonetheless indicate heightened exposure to terrorist financing or financial-crime risk. Screening against these sources allows early detection of red flags, captures in-country and emerging threats, and is consistent with FATF’s enhanced due diligence expectations for higher-risk geographies.

National sanctions screening with ATFS-HR is conducted via Dow Jones RiskCenter and draws on an extensive set of in-country terrorism designation, asset freeze, sanctions, and exclusion sources issued by regulatory and governmental authorities across dozens of jurisdictions worldwide. Only the lists maintained for the organization’s country of primary registration are screened, enabling detection of in-country enforcement actions that do not appear on primary multilateral or U.S. lists. Coverage varies by country, and for some jurisdictions no national list is available.

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Four-Tier Framework ›

Paragon’s Four-Tier Framework helps funders align vetting depth with risk.

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 ›