USA PATRIOT Act and Re-granting Compliance

USA PATRIOT Act and Re-granting Compliance Overview

Pursuant to the provisions of Executive Order 13224 and the USA PATRIOT Act, the Charles Stewart Mott Foundation requires all organizations doing re-granting with Mott funds to check the terrorism watch lists issued by the U.S. government and to refrain from providing financial or material support to any listed individual or organizations. (See your Mott grant agreement for this requirement.)

The list-checking requirement applies to our grantees — in the United States and abroad — that make their own grants to other individuals or organizations, using proceeds of the Mott grant. As explained in the “Distinguishing between ‘grants’ and ‘contracts for services’” section, grantees who only subcontract with Mott funds are generally not required to list-check their contractors.

This section of the Grantee Resources also contains a brief background on the counterterrorism measures adopted after September 11, 2001, our compliance procedures, what re-grantors need to do, further resources and software products to enable compliance, frequently asked questions, and a glossary of terms.

Because of the manner in which the lists are created and maintained and the similarity in names or portions thereof, the Foundation recognizes there can be mistakes on the list or the list-checking can create false positives. The Foundation is committed to working with its grantees to address any issues that may arise during the list-checking process.

If you have any questions about the Foundation’s process or your responsibility under the terms of the Grant Agreement, grantees should contact their program officer.

Remember that this area is complex and rapidly evolving. While we intend to update this section of the Grant Resources from time to time, this area — and Mott’s own compliance procedures and requirements — may change without being promptly reflected in the Grant Resources.

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