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 defined series of steps to ensure that funds are spent in accordance with a specific charitable purpose. Expenditure Responsibility is the preferred approach for project-specific grants or grants to organizations that are not recognized as IRS-certified public charities under Section 501(c)(3).

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.

For international grants, this service also includes watch list screening (SDN search, etc.) at the Silver Vetting level and review of foreign country requirements affecting the grantmaker and grantee.

 

New: Vetting Database

An organization appearing in the Paragon vetting database may be eligible for expedited or discounted vetting.

 
 

1. Pre-Grant Inquiry

  • Paragon Philanthropy conducts a thorough and disciplined pre-grant inquiry to help you meet regulatory requirements and ensure your grants are responsibly stewarded from the start. We obtain and review key organizational documents from the grantee to assess governance, legal standing, and program credibility. Our team carefully evaluates the grantee’s project narrative and proposed budget to confirm purpose, program feasibility, and mission alignment.

  • As part of our detailed review, we also collect and analyze additional information when applicable, including plans for capital expenditures or endowments, re-granting activities, scholarships and prize awards, lobbying or electioneering activities, and grants intended to provide food, shelter, or direct aid to the poor. This early-stage diligence helps identify and mitigate risks upfront, strengthens your compliance posture, and lays the foundation for a smooth, defensible grant lifecycle.

 
 

2. Review of Foreign Country Requirements (international only)

  • 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 (international only)

  • 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

  • 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

 
 

Selected Clients

Greater Houston Community Foundation

The Rockefeller Foundation

Chicago Community Trust

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