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. 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. In these environments, country-level conditions including elevated corruption or weak anti-money-laundering controls, as reflected in internationally recognized benchmarks such as Transparency International’s Corruption Perceptions Index and the Basel AML Index, may warrant enhanced scrutiny.
- 14 years Serving global grantmakers
- 100+ Countries, including higher-risk jurisdictions
- 3,000+ Vetted nonprofits in the registry
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 and certified disclosures on leadership, ownership, control, and banks | ✓ | ✓ |
| Global sanctions and watchlist screeningOrganization, governing body, key persons, controlling parties, and declared banks, with every potential match resolved | ✓ | ✓ |
| 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, via Dow Jones RiskCenter | – | ✓ |
| Adverse media reviewTerrorism- and financial-crime-focused, organization level | – | ✓ |
| 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
Who is screened
Screening steps
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 (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:
- 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
- United Nations Consolidated Sanctions List
- UK Sanctions List (FCDO)
- U.S. Terrorist Exclusion List
- Law enforcement sources
- FinCEN Section 311 special measures
- 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.
- 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 via 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
- 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 an auditable record of analyst actions 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.
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.
What the ATFS-HR Report contains
Executive snapshot
Every result on one page, from watchlist matches and bank screening to the policies provided and any escalation considerations.
Watchlist 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.
Country sanctions exposure
OFAC country-based sanctions programs for each reported country of activity, with applicable OFAC general licenses identified for the client’s review.
Adverse media and account status
Organization-level adverse media review, and the bank-issued account status documentation the organization provided.
Policies 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.
Escalation 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.
How it fits
ATFS-HR Within Paragon’s Four-Tier Framework
- Tier 1Anti-Terrorist Financing Screening (ATFS)Included in every ATFS-HR
- Tier 2Higher-Risk Anti-Terrorist Financing Screening (ATFS-HR)This service
- Tier 3Integrity Review (IR)Available when findings warrant escalation
- Tier 4Integrity Due Diligence (IDD)Available when findings warrant escalation
ATFS-HR corresponds to Tier 2 of Paragon’s Four-Tier Framework, which offers a scalable, risk-based approach to cross-border grantmaking, allowing funders to apply proportionate review levels based on identified risk factors. Beginning with baseline Anti-Terrorist Financing Screening (Tier 1, ATFS), each successive tier adds deeper layers of scrutiny, from enhanced sanctions and adverse media checks to integrity and registry-verified due diligence, enabling escalation only when warranted. This structured model aligns with FATF, IRS, OFAC, and global standards, balancing efficiency with robust risk mitigation in support of the client’s own risk decisions.
Why National Sanctions Screening?
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. Local 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 sub-national 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.
14 yearsServing global grantmakers
100+Countries, including higher-risk jurisdictions
3,000+Vetted nonprofits in the registry
Paragon’s Four-Tier Framework helps funders align vetting depth with risk.
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
