Expenditure Responsibility & Equivalency Determination


If you are a private foundation or a sponsoring organization of donor advised funds, our comprehensive back office compliance services allow you to give directly to foreign organizations and avoid the high, percentage-based fees of U.S. intermediaries.

To allow you more choice and flexibility in your international grantmaking, we offer both Expenditure Responsibility and Equivalency Determination and recommend which path to pursue.

Our Expenditure Responsibility and Equivalency Determination services include the Specially Designated Nationals (SDN) search, checking foreign grantees against the U.S. government's lists of organizations and individuals suspected or known to be involved in terrorism. Anti-terrorism financing screening is implemented at the Silver Vetting level.

Paragon's "white glove" services are characterized by a personalized relationship with our clients and a fast turn-around time for due diligence steps. We do not charge a membership fee.

Please contact us for more information about our services in international grants compliance.

Expenditure Responsibility

Expenditure Responsibility (ER) services for project-specific grantmaking. One low flat fee.

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Equivalency Determination

Equivalency Determination (ED) for general support grants. No membership fee.  

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International Grantmaking Policies and Procedures

Our team is available to review your foundation's policies and procedures for international grantmaking, or provide on-site training or coaching as needed. These services can be tailored to your specific needs. Please contact us for more information.


Paragon Philanthropy was a wonderful partner in assisting Omaha Community Foundation with an Equivalency Determination on a nonprofit in India. They were thorough with the work and end product, timely and always kept us up-to-date on our progress. We had complete confidence in the final product we received and were able to provide to a donor.
— Hillary Nather-Detisch, Director of Donor Accounts, Omaha Community Foundation

Selected Clients


The San Francisco Foundation

Whittier Trust

Greater Kansas City Community Foundation

Seattle International Foundation

Legacy Trust

Communities Foundation of Texas

Marin Community Foundation

Greater Houston Community Foundation

The Dallas Foundation