We ask organizations re-granting with Mott funds to comply with the provisions of the Executive Order and USA PATRIOT Act by:
- Cross-checking contact and organization information in their grants databases or grants listings with the OFAC-SDN terrorism watch list (see list-checking steps below); and
- Adopting changes to your grant agreements with your grantees to include prohibitions against violence or terrorist activities and re-granting.
- Permit the Mott Foundation to have access to your files and records for the purpose of verifying and documenting your organization’s list-checking procedures.
Step by step list-checking process for grantees
- For each grantee, check the organization name and address, primary project contact name, and primary organization contact name with the official terrorism watch list. The primary organization contact should be the individual that signs your grant agreement.
- Check the official terrorism watch list — The Specially Designated Nationals (SDN) List — prior to each payment processing.
- Any “hits” should be reviewed and documented as either a false positive or true positive. Your organization should take reasonable measures to confirm the identity of a “hit.” This may include, but is not limited to, 1) confirming the organization’s name and address by checking its governing documents, registration document, GuideStar tax status (U.S. organization), Form 990 or 990-PF (U.S. organization), and its employer identification number (U.S. organization); or 2) confirming the individual’s name, address and identification number (if any) by checking his/her passport, driver’s license or other identification.
- Any matches (true positives) should likewise be reviewed and documented. A hold should be placed on the pending transaction with the sub-grantee, and staff should contact the organization and seek clarification.