PLUS Service

A standalone service for grant payments, offered at two levels: PLUS, with ATFS, and PLUS Higher-Risk, with ATFS-HR.

The PLUS Service pairs Paragon’s Anti-Terrorist Financing Screening (ATFS), or its Higher-Risk Anti-Terrorist Financing Screening (ATFS-HR), with a set of safeguards for the grant payment itself. It is most often used when a valid Equivalency Determination (ED) is already in place and another international grant payment is due.

Each payment is treated as its own event, because funder and grantee circumstances can change quickly between payments. PLUS gives both funder and grantee confidence that each payment is handled responsibly and documented for the grant file.

PLUS is offered at two screening levels, set by the risk of the grant. Each level uses one of Paragon’s screening services, described in full on its own page.

Tier 1Baseline Screening

PLUSView ATFS

Tier 2Higher-Risk Screening

PLUS Higher-RiskView ATFS-HR

Compliance support

The PLUS Service

The PLUS Service comprises two service components:

Screening for the payment

Anti-Terrorist Financing Screening (ATFS), or ATFS-HR where the grant calls for higher-risk screening, renewed for the payment so that the grantee, the people who run it and its banks are screened against current sanctions and watchlists.

Additional safeguards

PLUS services deliver a targeted set of safeguards, including facilitation of grant agreement signatures when required, verbal verification of wire details, and an updated review of basic foreign country requirements. By combining these steps into one service, PLUS supports consistent oversight, reduces the risk of fraud or diversion, and helps keep the grant file complete and well organized.

PLUS Service Components

Anti-Terrorist Financing Screening (ATFS) is part of every PLUS engagement. The other components are included in the service and applied as each grantmaker’s needs require.

Anti-Terrorist Financing Screening (ATFS)

The PLUS Service includes ATFS, Paragon’s baseline anti-terrorist financing screening service and Tier 1 of the Four-Tier Framework. Paragon manages all communications with the foreign grantee; collects and reviews core organizational documents; secures documentation of current legal registration status; and obtains either a certified list of persons with operational authority, board members, founders, beneficial owners, controlling entities and controlling individuals, and financial institutions, or formal confirmation that no changes have occurred. Paragon verifies updates to banking relationships, screens all relevant names and entities against U.S. and international sanctions and watchlists (including OFAC, UN, EU, UK, FBI, and Interpol), conducts follow-up analysis on potential matches, secures additional information from the grantee as needed, and generates a written screening report with full supporting documentation for the grant file. PLUS Higher-Risk uses Paragon’s enhanced anti-terrorist financing screening service (ATFS-HR) instead. Each PLUS engagement covers one grant payment.

Why

Anti-terrorist financing screening is essential in cross-border grantmaking to reduce the risk that charitable funds are diverted to organizations or individuals associated with terrorism, money laundering, or other sanctioned activities. Risks may arise at any time due to changes in leadership, board composition, controlling entities, banking relationships, or registration status. Global watchlists (OFAC, UN, EU, UK, FBI, Interpol, and others) are continually updated. By verifying updates, confirming no changes, and re-screening the grantee before each disbursement, ATFS reduces the risk of inadvertently transferring funds to a sanctioned party and provides clear, documented support for compliance reviews.

Grant Agreement Signatures and Communications

Coordinating execution of the grant agreement by the grantee and client representatives through a secure e-signature platform, while facilitating communications between the parties to address any questions that may arise regarding the agreement. This process helps ensure that signatures are secure, time-stamped, and verifiable, creating a clear record for compliance and audit purposes. This service expressly excludes any legal review or analysis of the grant agreement.

Why

A signed agreement allows the grantor to reaffirm protective language around the charitable use of funds, compliance with anti-terrorist financing and sanctions laws, and adherence to reporting obligations. By requiring grantee and client signatures for each installment, the agreement provides that funds are disbursed under updated terms, protecting the grantor against misuse, diversion, or reputational risk while aligning with compliance expectations.

Wire Information and Confirmation of Receipt

This service includes the following steps:

Securing wire information via secure e-signature platform
Verbal verification of wire details
Confirming receipt of funds by the grantee

Paragon compiles these steps into a report, creating a clear record that the payment was authorized, transmitted, and received as intended.

Why

Reconfirming and verifying wire details prior to each payment helps prevent costly errors and fraud, such as misdirected or spoofed wires, and ensures funds are documented as received as intended. By securing wire instructions in writing, verbally confirming no changes, and obtaining confirmation of receipt from the grantee, the client reduces diversion risk and keeps a clear record of each payment for compliance reviews.

Basic Foreign Country Requirements Review

This is a three-step review: (i) check the ICNL Civic Freedom Monitor for the relevant country; (ii) review the Council on Foundations (COF) Country Note; and (iii) request that the grantee identify which requirements apply when receiving foreign funding. Because these rules can change between payments, the review reconfirms applicable obligations each time. Information is included only if published by ICNL or COF. For countries not covered by these sources, clients may request Paragon’s Enhanced Foreign Country Requirements Review (EFCR). This review is informational only and does not constitute legal advice.

Why

Many jurisdictions impose registration, reporting, or approval requirements on nonprofits receiving foreign funding, and in some cases on U.S. grantmakers as well. Because these rules can change quickly, reviewing them before each disbursement provides an important safeguard. Noncompliance may delay transfers, expose the grantee to penalties, or risk suspension of operations. By consulting authoritative sources (ICNL, COF) and confirming requirements with the grantee, this review provides current reference points on restrictions that may affect a grant’s legality or safety, helping protect both funder and grantee.

Documentation Provided

At the close of each PLUS engagement, the client receives the following documentation for its grant file:

Due diligence and compliance

ATFS Report

Anti-Terrorist Financing Screening (ATFS) report with screening logs and exhibits (standard service level)

ATFS-HR Report

Higher-Risk Anti-Terrorist Financing Screening (ATFS-HR) report, provided when the Higher-Risk service level is requested

PLUS Higher-Risk

Foreign Country Requirements Summary

With supporting evidence

Grant execution

Grant Agreement E-Signatures

Secure e-signature facilitation of grant agreement signatures

If requested

Wire Verification Record

Wire instructions secured in writing, a record of the verbal verification of wire details, and confirmation of receipt

If requested

**When Clients Use PLUS on Its Own**

As a standalone service, PLUS is used for a grant payment that needs current screening and payment safeguards but not a new ED: most often a further payment to a grantee whose ED is still valid. Where a new ED is needed, Paragon’s ED PLUS includes the same safeguards.

Timeline and Delivery

Timing depends mainly on how quickly the grantee supplies the requested information and documents, including any updates since the last payment. Paragon provides status updates through the portal at each stage, from document collection through delivery of the screening report and payment records.

Limitations

The PLUS Service provides administrative safeguards and documentation; it does not constitute legal, financial, or tax advice. Final compliance decisions, including how to address flagged issues or whether to proceed with a payment, remain with the client and, where appropriate, its counsel.

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