Government Entity PLUS


Neither Equivalency Determination nor Expenditure Responsibility is required to qualify foreign governmental entities for an international grant. Instead, specific documentation from a governmental grantee is obtained to demonstrate government ownership or control. A grant agreement is required, but reporting is not. Examples of governmental entities include public colleges and universities, cities, school districts, and water districts.

Paragon's service for qualifying government agencies, instrumentalities and political subdivisions includes watch list screening (SDN search, etc.) at the Silver Vetting level, review of foreign country requirements, and review of the grant agreementWe handle all communications with the foreign grantee, 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:


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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. Initial Documentation

  • Obtain key documents (affidavit and specific backing documents based on the type of governmental entity)

  • Review foreign country prerequisites affecting international grantmaking (such as special registration requirements)



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

  • Review and transmit the grant agreement and related documents to the grantee and secure signatures.



5. Wire Transfer Information & Receipt of Funds

  • Secure the grantee’s international wire transfer information

  • Confirm grantee receipt of funds