Staying Legal: List Checking Best Practices September 16, 2010 Audio is only available by calling this number: Conference Call: 866-740-1260; Access Code: 6339392

Using ReadyTalk Chat & raise hand All lines are muted If you lose your internet connection, reconnect using the link emailed to you. If you lose your phone connection, re-dial the phone number and re-join. ReadyTalk support: 800-843-9166 2

You are being recorded… This seminar will be available on the TechSoup website along with past webinar presentations: www.techsoup.org/go/webinars You will receive a link to this presentation, material and links. Twitter hashtags: #techsoup 3

Staying Legal: List Checking Best Practices Presenters: Cindy Compeau, Emily Chessin, Francia Fajardo

We are working toward a time when every nonprofit and social benefit organization on the planet has the technology resources and knowledge they need to operate at their full potential TechSoup.org offers nonprofits a one-stop resource for technology needs by providing free information, resources, and support. In addition to online information and resources, we offer a product philanthropy service through which nonprofits can access donated and discounted technology products, generously provided by corporate and nonprofit technology partners.

www.techsoup.org

Today’s Speakers Cindy Compeau Emily Chessin Francia Fajardo Charles Stewart Mott Foundation Emily Chessin World Resources Institute Francia Fajardo TechSoup Global Facilitator: Kami Griffiths, TechSoup Global Assisting with chat questions: Jennifer Beckett, TechSoup Global 7

Agenda About Charles Stewart Mott Foundation USA PATRIOT Act Compliance Mott’s Requirements for List-checking Find, research, documentation Manual search demo Batch search demo Q&A

www.mott.org

The Mott Foundation & USA PATRIOT Act Compliance Pursuant to the provisions of Executive Order 13224 and the USA PATRIOT Act, the Charles Stewart Mott Foundation and all organizations doing re-granting with Mott funds are required to check one terrorism watch list issued by the U.S. government—Specially Designated Nationals (SDN) list—and to refrain from providing financial or material support to any listed individuals or organizations. The list-checking requirement applies to Mott and all Mott grantees – in the United States and abroad – that make their own grants to other individuals or organizations, using funds from the Mott grant.  Mott reviews this policy annually.

Mott’s Requirements for List-checking Check the OFAC-SDN watch-list prior to writing each grant (Office of Foreign Assets Control, Specially Designated Nationals and Blocked Persons) http://www.treas.gov/offices/enforcement/ofac/sdn/ Check the organization name, primary project contact name, and primary organization contact name with the official watch-list required by Mott Check the official watch-list prior to writing each grant cheque Any “hits” should be reviewed and documented as either a false positive or true positive For true positives, do not continue to process the payment; contact your Mott program officer to seek clarification Mott recommends that any grant agreement include prohibitions against violence or terrorist activities and re-granting

Finding a Match (a “Hit”) & Documenting If any of your grantee’s information matches information from your search of the watch-list you must verify that the information is false If a rare case turns up true information, you must contact your Mott Program Officer before making a grant payment. Document your list-checking and verification Record the results of the list-check and any verification you did Print the results and file the hard copy Save the results to a file on your computer Retain your records During the term of the grant For five years thereafter

Research & Document “Hits” Verify the organization name and address using Governing documents Registration document GuideStar: http://www.guidestar.org/ (US orgs only) Form 990 or 990-PF tax returns (US orgs only) Employer Identification Number (US orgs only) Verify individuals’ names, addresses, and ID numbers using Passport Driver’s license Other government-issued identification

Documentation Process Document your verification Record the results of the list-check and any verification you did Print the results and file the hard copy Save the results to a file on your computer Retain your records During the term of the grant For five years thereafter

www.mott.org/resources.aspx

Manual List-Checking Demo Emily Chessin

Manual List Checking Process Visit the OFAC-SDN site Download the latest .pdf file Do three searches per grantee (organization name, name of director, name of project manager). After each check make a “print screen” showing the name searched and the result given. Paste the screen shot into a Word document and include the name of the organization, the name searched, the search date and a space for the signature of the staff member who did the checking. File the Word documents electronically by organization; three documents for the three checks done. Print the Word documents to be signed by the staff member who carried out the check. File these paper documents by organization with other documents collected as part of the due diligence process on that organization. 17

Batch List-Checking Demo Francia Fajardo

Resources TechSoup created information for grantees of the Mott Foundation: www.techsoup.org/mott Program officers or grant administration staff at your funder’s organization for funder requirements for re-granting their funds More on Executive Order 13224: http://tinyurl.com/26g8xdh More on the USA PATRIOT Act: www.fincen.gov/statutes_regs/patriot/index.html

Submit your questions using the chat box.

Upcoming Webinars Social Media Decision Making Tuesday, September 21, 11 a.m. Pacific Donor Management Solutions Thursday, September 30, 11 a.m. Pacific

Thank you. Please complete the post event survey Thank you! Please complete the post event survey! For more information contact mott@techsoup.org