Integrity Review

Integrity Review (IR) builds directly on Paragon’s Tier 1 Anti-Terrorist Financing Screening and Tier 2 Higher-Risk Anti-Terrorist Financing Screening, and includes all screening, verification, and escalation steps performed at those levels. In addition to sanctions/watchlist, and enhanced jurisdictional screening, Integrity Review expands due diligence to address corruption, governance, political exposure, and reputational risk that may affect a grantee’s credibility.

Integrity Review is the third tier of Paragon’s Four-Tier Framework. Escalation to IR is recommended when risks include corruption, fraud, organized crime, political exposure, material subcontractors or vendors, governance gaps, or elevated-risk geographies.

Screening at this level includes PEP checks and reputational adverse media across the entity, key persons, financial institutions, and disclosed vendors/subcontractors. Control relationships are screened at the entity-name level against sanctions, PEP, and adverse media, with full reviews available under higher tiers if warranted. Governance and accountability policies are reviewed alongside procurement and conflict of interest policies, and geography risk ratings are applied. Where intermediary or correspondent banks have been identified, Integrity Review evaluates available reputational and corruption-related risk indicators to assess potential vulnerabilities in payment routes. This stage delivers a broad integrity review of the grantee and its ecosystem.

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View this service within the Four-Tier Framework ›
Paragon’s risk-based due diligence framework helps funders align vetting depth with risk.
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Selected Clients

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

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