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OthersThe US Patriot ActThe US Patriot Act:Pursuant to the provisions of Executive Order 13224 and the USA PATRIOT Act, the Vijay Amritraj Foundation requires all organizations doing re-granting with VAF 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 VAF 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 VAF grant. As explained in the "Distinguishing between ‘grants' and ‘contract services'" section, grantees who only subcontract with VAF funds are generally not required to list-check their contractors. This section of the Grants Kit also contains a brief background on the counter-terrorism 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 the Foundation or their appointed VAF Ambassador. Remember that this area is complex and rapidly evolving. While we intend to update this section of the Grant Kit from time to time, this area - and the VAF's own compliance procedures and requirements - may change without being promptly reflected in the Grant Kit Grantee VAF USA Patriot Act Compliance Requirements What re-granting organizations need to do Re-granting: The redistribution of grant funds from VAF to support one or more organizations or hire services. We ask organizations re-granting or subcontracting with VAF funds to comply with the provisions of the Executive Order and PATRIOT Act by: · Cross-checking contact and organization information in their grants databases or grants listings with the official terrorism watch list; and · Adopting changes [see step 5 below] to your grant agreements with your grantees. Step by step list-checking process for grantees1.For each grantee, check the organization name and address, primary project contact name, and primary organization contact name with the official terrorism watch list. (Available through the VAF) The primary organization contact should be the individual that signs your grant agreement. 2.Review with VAF staff/Ambassador the official terrorism watch list -- The Specially Designated Nationals (SDN) List -- prior to each funding receipt. 3.If there is evidence or concern that an organization is noncompliant, the organization must perform due diligence. This may include, but is not limited to, (1) confirming the organization's name and address by checking its governing documents, registration document, or (2) confirming the individual's name, address, and identification number (if any) by checking his/her passport, driver's license, or other identification. 4.Any matches 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 VAF to seek clarification. 5.We recommend that any grant agreement include prohibitions against violence or terrorist activities and re-granting. 6.Permit the VAF to have access to your files and records for the purpose of verifying and documenting your organization's list-checking procedures. 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 VAF grant. As explained in the “Distinguishing between ‘grants’ and ‘contract services’” section, grantees who only subcontract with VAF funds are generally not required to list-check their contractors. This section of the Grants Kit also contains a brief background on the counter-terrorism 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 the Foundation or their appointed VAF Ambassador. Remember that this area is complex and rapidly evolving. While we intend to update this section of the Grant Kit from time to time, this area - and the VAF’s own compliance procedures and requirements - may change without being promptly reflected in the Grant Kit Grantee VAF USA Patriot Act Compliance Requirements What re-granting organizations need to do Re-granting: The redistribution of grant funds from VAF to support one or more organizations or hire services. We ask organizations re-granting or subcontracting with VAF funds to comply with the provisions of the Executive Order and PATRIOT Act by: · Cross-checking contact and organization information in their grants databases or grants listings with the official terrorism watch list; and · Adopting changes [see step 5 below] to your grant agreements with your grantees. Step by step list-checking process for grantees 1.For each grantee, check the organization name and address, primary project contact name, and primary organization contact name with the official terrorism watch list. (Available through the VAF) The primary organization contact should be the individual that signs your grant agreement. 2.Review with VAF staff/Ambassador the official terrorism watch list -- The Specially Designated Nationals (SDN) List -- prior to each funding receipt. 3.If there is evidence or concern that an organization is noncompliant, the organization must perform due diligence. This may include, but is not limited to, (1) confirming the organization’s name and address by checking its governing documents, registration document, or (2) confirming the individual’s name, address, and identification number (if any) by checking his/her passport, driver’s license, or other identification. 4.Any matches 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 VAF to seek clarification. 5.We recommend that any grant agreement include prohibitions against violence or terrorist activities and re-granting. 6.Permit the VAF to have access to your files and records for the purpose of verifying and documenting your organization's list-checking procedures. ~ ngoportal 05/6/2013 |
