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 agreement. We 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:
Selecting the correct approach
Before proceeding with Equivalency Determination, Expenditure 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