Expenditure Responsibility Service

Expenditure Responsibility (ER) is often the most cost-effective way to make a direct cross-border grant.  It is also the favored approach when making project-specific grants, or grants to organizations that would not likely qualify under Equivalency Determination. Our team manages the following steps in the ER process for your foundation or donor advised fund, from pre-grant inquiry to closeout, and we handle all communications with the foreign grantee. Unlike U.S. intermediary organizations, whose fees can range from 8-15% of the grant amount, Paragon offers Expenditure Responsibility for a flat fee of $850 per grant (for grants under $100,000).


1. Pre-Grant Inquiry

  • Obtain and review key organizational documents from the grantee
  • Review the grantee's project narrative, budget, and the charitable purpose of the grant
  • Screen for capital expenditures and endowments
  • Screen for re-granting
  • Screen for lobbying and electioneering
  • Collect backing documentation for scholarships and prizes
  • Obtain backing documentation for grants for food, shelter, and aid to the poor


2. Review of Foreign Country Requirements

  • Review regulations in the foreign country affecting the grantee and the grantmaker, and verify compliance. Alert client to any foreign country restrictions on the operations of civil society organizations that might be of particular concern.


3. SDN Search / USA Patriot Act Compliance

  • Conduct the SDN Search
  • Review the Terrorist Exclusion List
  • Review OFAC Sanctions Programs for the countries in which the grantee is operating
  • Repeat the SDN Search as needed


4. Grant Agreement

  • Based on the pre-grant inquiry, generate a validation letter recommending preparing the grant agreement
  • Recommend specific language for the charitable purpose of the grant
  • Review the grant agreement for required Expenditure Responsibility language
  • Obtain grantee signatures on the grant agreement and any related documents


5. Wire Transfer Information & Receipt of Funds

  • Secure the grantee’s international wire transfer information
  • Confirm grantee receipt of funds


6. Reporting

  • Prepare the grant-specific reporting template
  • Adapt the template for custom reporting needs
  • Enter reporting deadlines into our system and schedule reminders
  • Collect report(s) from the grantee
  • Review report(s) and request grantee revisions as needed


7. Closeout

  • Conduct our final reporting review in strict accordance with Expenditure Responsibility guidelines
  • Recommend the grantmaker accept (or in rare cases, reject) the report