1. Staying Legal: List Checking Best Practices September 16, 2010
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4. Staying Legal: List Checking Best Practices
Presenters: Cindy Compeau, Emily Chessin, Francia Fajardo

5. 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.

7. 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

8. 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

10. The Mott Foundation & USA PATRIOT Act Compliance
Pursuant to the provisions of Executive Order 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.

11. 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)
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

12. 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

13. Research & Document “Hits”
Verify the organization name and address using
Governing documents
Registration document
GuideStar: (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

14. 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

16. Manual List-Checking Demo
Emily Chessin

17. 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

18. Batch List-Checking Demo
Francia Fajardo

19. Resources
TechSoup created information for grantees of the Mott Foundation:
Program officers or grant administration staff at your funder’s organization for funder requirements for re-granting their funds
More on Executive Order 13224:
More on the USA PATRIOT Act:

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

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