Services
For Grantmakers Engaged Across Borders
Paragon’s services are organized to help grantmakers manage third-party risk, regulatory complexity, and jurisdictional exposure across the full lifecycle of cross-border grantmaking.
Third-Party Risk
Paragon’s Third-Party Risk services address integrity, financial crime, and reputational risks that arise when grantmakers engage organizations, intermediaries, and financial channels across borders. These services help funders identify and manage exposure to terrorist financing, corruption, political influence, sanctions risk, and related third-party vulnerabilities that may affect cross-border giving.
These services are distinct from grant administration and charitable-use compliance, which focus on how funds are deployed and monitored. Third-party risk due diligence instead evaluates the integrity, ownership, governance, operating environment, and exposure profile of counterparties themselves.
Reviews draw on a coordinated set of screening and analytical tools, including sanctions and terrorism screening, politically exposed persons (PEP) checks, adverse media review, State-Owned Enterprise analysis, and country-level risk assessment. These tools provide evidence-based insight into organizational credibility and contextual risk and may be applied on a standalone basis or within a structured review.
The Four-Tier Framework
To ensure consistency and proportionality, Paragon organizes its core third-party risk offerings under its risk-based due diligence framework, the Four-Tier Framework. Within this framework, Anti-Terrorist Financing Screening, Higher Risk Anti-Terrorist Financing Screening, Integrity Review, and Integrity Due Diligence are offered as discrete service tiers. Each tier represents a defined scope of review that integrates multiple analytical components and escalates only when specific risk indicators are identified. This structure enables funders to apply appropriate rigor in higher-risk contexts while maintaining efficiency where risks are limited. The following services represent the four tiers.
Tier 1
Anti-Terrorist Financing Screening
Establishes the baseline for cross-border due diligence by screening organizations, leadership, and banking relationships against global terrorism and sanctions lists to identify potential exposure to terrorist financing risk.
Tier 2
Higher Risk Anti-Terrorist Financing Screening
Builds on baseline anti-terrorist financing screening by expanding sanctions, adverse media, and banking checks to address elevated risk associated with higher-risk geographies, complex operations, or government-linked entities.
Tier 3
Integrity Review
Builds on higher-risk anti-terrorist financing screening to assess corruption, governance, political exposure, and reputational risk through expanded PEP screening, adverse media review, and policy analysis across leadership, partners, and financial channels.
Tier 4
Integrity Due Diligence
Builds on the Integrity Review by applying enhanced verification, litigation and enforcement record searches, and expanded ownership mapping to document integrity-related risks in higher-risk or complex grantmaking environments.
Complementary Screening and Risk Services
In addition to tiered due diligence reviews, Paragon offers complementary screening and validation services that support proportionate risk assessment across the grantmaking lifecycle. These services help surface specific risk signals, confirm organizational legitimacy, and inform decisions about whether deeper engagement is warranted. Some operate as analytical components within Paragon’s Four-Tier Framework, while others provide rapid, non-contact validation at the earliest stages of vetting.
Targeted Risk Screening Services
Targeted Risk Screening Services provide focused insight into specific categories of third-party risk commonly encountered in cross-border grantmaking. These services are designed to surface defined risk indicators related to political exposure, financial controls, and reputational harm, supporting informed decision-making at discrete points in the grantmaking lifecycle. Each service may be engaged on a standalone basis to address a specific risk question or applied within Paragon’s Four-Tier Framework as part of a broader, proportionate review.
Politically Exposed Persons Screening
Identifies political exposure by screening organizations and key individuals against global PEP databases, helping funders assess corruption, influence, and reputational risk linked to politically connected leadership or counterparties.
Adverse Media Screening
Monitors global media sources to surface historical or emerging reputational concerns, including fraud, corruption, financial misconduct, or other material issues, that may be relevant to grantmaking decisions.
Financial Health & Controls Screen
Reviews submitted financial and governance documentation to identify indicators of financial weakness, control gaps, or operational risk. Supports early assessment of an organization’s financial capacity and stewardship practices.
Rapid Validation Services
Rapid Validation Services are non-contact, registry-based reviews designed to support early-stage vetting before funders commit staff time, request documents, or initiate formal compliance or due diligence processes. These services rely exclusively on publicly available sources and do not involve engagement with the organization under review. Nonprofit Validation provides a focused confirmation of legal registration, public benefit status, and organizational legitimacy. Rapid Validation & Screening builds on this foundation by incorporating nonprofit validation alongside additional risk-based screening, including sanctions, politically exposed persons, and adverse media checks.
Nonprofit Validation Service
A no-contact verification of an organization’s legal nonprofit status and public benefit purpose based on official registries and public documentation.
Rapid Validation & Screening
A no-contact, early-stage screening that helps funders determine whether a prospective organization warrants deeper due diligence, integrating nonprofit validation with sanctions, politically exposed person (PEP), and adverse media screening.
Jurisdictional Risk & Foreign Country Requirements
The risk of fund diversion, financial crime, and regulatory noncompliance varies significantly across jurisdictions, influenced by governance quality, corruption levels, terrorist activity, and the strength of local financial oversight. Through jurisdiction-specific reporting, Paragon examines exposure to money laundering, corruption, and terrorist financing, with particular attention to conditions that affect nonprofit integrity and accountability. Complementing this research, Paragon’s foreign country requirements reviews identify the in-country regulations and restrictions that govern the receipt of foreign funding, enabling clients to anticipate compliance obligations, protect grantee operations, and sustain lawful, transparent charitable partnerships worldwide.
Country Risk Report
A country-level analysis of governance conditions, financial crime exposure, and nonprofit sector risk. The report synthesizes corruption, AML/CFT environment, regulatory effectiveness, and operating context to help funders understand how national conditions may shape risk exposure and diligence needs.
Review of Foreign Country Requirements
A jurisdiction-specific review that surfaces known laws, administrative requirements, and restrictions affecting foreign funding of nonprofits. The review highlights considerations funders may need to account for when structuring, timing, or implementing cross-border grants.
Compliance Support for Cross-Border Grantmaking
For U.S.-based grantmakers, Paragon provides operational support for international grantmaking compliance, including Expenditure Responsibility and Equivalency Determination. We manage documentation, coordinate grantee communications, and support pre- and post-grant compliance workflows, with final legal determinations and opinion letters issued by independent qualified professionals. Paragon does not provide legal advice.
Standard Expenditure Responsibility and Equivalency Determination engagements include baseline Anti-Terrorist Financing Screening (Tier 1) under the Four-Tier Framework, providing initial sanctions and terrorism exposure screening prior to grant approval. For engagements involving elevated risk indicators, Paragon offers enhanced ER and ED services that incorporate Higher-Risk Anti-Terrorist Financing Screening (Tier 2), expanding sanctions, terrorism, and adverse media screening in proportion to the risk context.
Where compliance processes alone do not provide sufficient visibility into third-party integrity or operational risk, funders may elect to supplement ER or ED with Paragon’s Tier 3 Integrity Review or Tier 4 Integrity Due Diligence. These services provide deeper assessment of governance, financial controls, ownership structures, and reputational risk in complex or higher-risk environments.
Equivalency Determination PLUS
Manages the full Equivalency Determination workflow, including documentation collection, grantee coordination, and liaison with an independent qualified tax practitioner. Designed for standard-risk grants requiring a formal ED opinion. Includes baseline Anti-Terrorist Financing Screening (Tier 1).
U.S. Only
Equivalency Determination PLUS Higher Risk
Includes the full Equivalency Determination PLUS workflow, augmented with enhanced anti terrorist financing and sanctions screening aligned with Tier 2 of the Four-Tier Framework. Intended for higher-risk jurisdictions, sectors, or funding contexts.
U.S. Only
Expenditure Responsibility PLUS
Facilitates Expenditure Responsibility compliance from pre-grant due diligence through post-grant reporting. Supports funders in meeting IRS requirements while streamlining operational execution. Includes baseline Anti-Terrorist Financing Screening (Tier 1)
U.S. Only
Expenditure Responsibility PLUS Higher Risk
Builds on Expenditure Responsibility PLUS by incorporating enhanced anti terrorist financing and sanctions screening consistent with Tier 2 of Paragon’s Four-Tier Framework. Appropriate where elevated jurisdictional, sectoral, or counterparty risk is present.
U.S. Only
Strategic Grantmaking Support
Paragon Philanthropy provides strategic grantmaking support grounded in cross-border research, risk awareness, and deep field insight. We draw on a distinguished roster of Senior Advisors with deep issue-area expertise and a global network of NGO and nonprofit partners. Through this combination of field knowledge and institutional experience, we help funders identify credible partners, navigate complex operating environments, and direct resources where they can achieve meaningful, sustained impact.
We support global grantmakers operating in challenging and high-stakes contexts, including new portfolio development, crisis response, and work in fragile or post-conflict settings. Paragon advises foundations, corporations, DAF sponsors, and philanthropic institutions across the European Union, United States, Canada, United Kingdom, Switzerland, and Australia, helping translate mission intent into pragmatic, risk-aware strategies.
Drawing on our curated database of more than 4,000 pre-vetted nonprofits, rapid vetting tools, and deep sector expertise, we help clients move efficiently from exploration to action, mitigating risk while remaining responsive to emerging needs. Our Grantee Research & Portfolio Development services provide structured support for identifying, assessing, and assembling mission-aligned portfolios that reflect both global perspective and local context.
Grantee Research & Portfolio Development
Strategic sourcing, landscape analysis, and portfolio design
Structured research and analysis to support strategic sourcing, landscape mapping, and portfolio design in cross-border philanthropy. This work helps funders understand the operating context, identify credible organizations, and assemble portfolios that reflect both risk considerations and strategic priorities.
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
