USA PATRIOT Act and Re-granting Compliance

Mott’s Compliance Procedures

In addition to program officer, grants administration and management due-diligence procedures, Mott is complying with the provisions of the Executive Order and USA PATRIOT Act by:

  • Cross-checking contact and organizational information in our grants database with OFAC-SDN terrorism watch lists (list-checking); and
  • Adopting changes to our grant agreement.

First, in order to perform the required list checking, we purchased software from LexisNexis. Bridger Insight is a cumulative tracking solution using data lists required by the Executive Order and USA PATRIOT Act. It is customizable, fast, and has the ability to check names individually or in batch. The software creates and maintains clear audit trails and allows the Foundation to compile and print detailed reports. On legal counsel’s advice, we are crosschecking our grants database with Bridger Insight prior to each biweekly check run and once a month for all open grants. We cast a broad net, checking all contacts and organizations affiliated with either the request or the organization.

Second, on legal counsel’s advice, we have changed our grant agreement to include prohibitions against violence or terrorist activities and re-granting (unless re-granting is specifically approved in the grant budget). Legal counsel has advised us to require all approved re-granting organizations to check the terrorism watch lists and refrain from providing financial or material support to any listed individual or organization.

The Mott Foundation’s step by step list-checking process

  1. Using a database utility developed internally, we export a file listing organization and contact names appropriate for the crosscheck we are performing (pending payments and open grants).
  2. We launch our list-checking software (Bridger Insight), verify the government watch lists are up to date, and execute a scan of the export file.
  3. Any “hits” are reviewed and documented as either a false positive or true positive.
  4. Any matches (true positives) are likewise reviewed and documented. A hold is placed on the pending transaction with the grantee, and program staff is contacted to notify the grantee and seek clarification. Thus far, we have not encountered a match.