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 review core identifying, governance, and financial information, supported by appropriate documentation and supplemented by relevant public-source review where available. These inputs, certified as accurate by the organization, provide the evidentiary basis for sanctions, watchlist, adverse media, and contextual risk screening across applicable jurisdictions. 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 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 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.
• 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 confirming current legal status (e.g., certificate of registration, charter, or equivalent).
• 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.
• 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 review of bank-issued account status documentation (see Step 6).
• 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: OFAC SDN and SSI; OFAC-related lists (FSE, CAPTA, NS-MBS, NS-CMIC, Non-SDN PLC, and the Department of State Cuba Restricted List); European Union sanctions; the United Nations Consolidated Sanctions List; UK HM Treasury sanctions; the U.S. Terrorist Exclusion List; FBI and Interpol lists; and FinCEN Section 311 special measures. Screening is conducted via CSI WatchDOG Elite.
• 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. 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 National Sanctions Sources below).
• 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, and any designation identified is recorded.

3. Adverse Media and Contextual Risk Analysis

• Conduct terrorism-focused Adverse Media Screening (AMS) on the organization, 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) and record whether the documents provided support the organization’s stated positions.

6. Bank-Issued Account Status Documentation

• Paragon requests bank-issued documentation of the organization’s account status and records what it states regarding the organization’s primary banking institution and active accounts, including any indications of account freezes, regulatory restrictions, or adverse actions by the bank. The purpose of this step is to record what the document states about whether the grantee’s accounts have been flagged or restricted for suspected illegal activity, money laundering, or terrorist financing, and about the organization’s banking relationship; Paragon does not itself confirm that an account is in good standing. Documentation or confirmation of banking status is obtained directly from the organization and retained in the screening record.

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.