Practical guide

Sanctions screening for nonprofits: partner and grant checks

Check nonprofit partners and grant recipients, review possible sanctions matches, and keep separate approval and legal assessments linked to the program file.

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Identify the legal partner behind the program

Use SanctionsKit for the partner, supplier or other party your nonprofit's process requires. Start with the legal name and grant reference. A project name or familiar contact may not identify the company or group that will receive the funds.

Collect the facts needed for that purpose through your approved process. Do not enter every person who receives aid into a commercial system without a clear reason and rules for handling the data. A name check cannot decide whether an aid activity is allowed or obtain a license.

Screen the selected party and keep its reference

Open New screening. Enter the legal name, type and known registration details. If you need later checks, create a saved profile. Use External reference for your own partner ID so the team can find the right record.

Choose the approved policy and required available sources, then Run screening. Use invented records in Sandbox to practice. Real partner checks need authorized Production access. Save the result ID in the grant file. If a required source is unavailable, the check is still incomplete.

Investigate the candidate without assuming identity

In the Review queue, compare the source entry with facts you trust about the partner. State which facts agree or conflict and which remain unknown. A shared nationality or common contact name does not prove it is the same party.

For a fictional partner carrying out a grant, ask for a missing company ID through the approved channel. Leave the candidate open until enough evidence is reviewed. Use neutral terms and limit access. Record the identity finding first, then the separate business decision and any required approval.

Connect the program's authorization assessment

Your program may need a separate review of ownership, the planned activity or a license. An admin can require that work in Screening policies. In the case, record that it was done externally and link the evidence. If it does not apply, state why.

Keep relevant advice and approval documents in approved storage. Link the file version and program context from the case. A no-match or dismissed candidate cannot show that a grant, transfer or aid activity is legally permitted. The team responsible for that question must still assess it.

Handle a changed subrecipient or continuing partner

If a fictional grant adds a new subrecipient, check that group as a separate legal party when required. Keep the original partner's result and link the new one to the grant change. The first result cannot cover a different group.

For ongoing partners chosen by policy, create Monitoring with the saved profile. Assign a person to follow up on alerts and failures. Use the evidence workflow to export retained case records. Keep the original files and their storage rules in the approved repository.

Sources and references

Frequently asked questions

Should a nonprofit screen the project name or implementing organization?

Check the legal party your policy requires. A project name belongs in the grant context and may not name the group receiving funds. Confirm who the partner is before choosing the subject for the search.

Does a nonprofit partner no-match authorize a grant or transfer?

No. It means the submitted identity had no candidate in the selected sources. The responsible team still needs to assess any rules about ownership, the activity or required approval, and keep evidence of that work.

How should a nonprofit handle a common-name candidate fairly?

Describe it as a possible match and ask for facts that can distinguish the parties. Do not assume identity from a name or nationality. Leave the finding open when the facts do not yet support a decision.

Can the original grantee result cover a new subrecipient?

No. Treat the new group as a separate legal party and run the required check. Link the result to the grant change while keeping the first partner's record and the program's wider assessments.