Expenditure Responsibility PLUS


“Working with Paragon reduces the burden on our team and gives us the confidence that foreign grantees have been thoroughly vetted. We appreciate Paragon’s excellent customer service, knowledge of international grantmaking compliance, and fast turn-around.”

— Krystle Folse, Director of Donor Services, Greater Houston Community Foundation



Through Expenditure Responsibility, a grantmaker carries out a series of steps in order to make sure that funds are spent according to a specific charitable purpose. Expenditure Responsibility is the favored approach when making project-specific grants, or grants to organizations that would not likely qualify under Equivalency Determination.

In addition to required Expenditure Responsibility steps, Expenditure Responsibility PLUS includes watch list screening (SDN search, etc.) at the Silver Vetting level and review of foreign country requirements affecting the grantmaker and grantee. We handle all communications with the foreign grantee, review required documents, secure grantee signatures, obtain wire transfer information, and confirm receipt of funds.

Our team manages the following steps for your family foundation, corporate foundation, or donor advised fund, from pre-grant inquiry to closeout:


Selecting the correct approach

Before proceeding with Equivalency DeterminationExpenditure Responsibility, or special qualifying procedures for governmental entities, we review the circumstances of the grant and recommend the most appropriate compliance approach.


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. Anti-Terrorist Financing Screening

  • Conduct anti-terrorism financing screening (SDN search, etc.) at the Silver Vetting level

  • Review OFAC Sanctions Programs for the countries in which the grantee is operating

  • Repeat screening 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