Frequently Asked Questions
The USA PATRIOT Act and List-checking
- Q. Where can I find out about the USA PATRIOT Act?
- A. We encourage you to become more familiar with the potential impact of the USA PATRIOT Act by reading the following:
- Q. Why do you capitalize the letters in USA PATRIOT Act?
- A. USA PATRIOT Act is an acronym for Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act.
- Q. “List checking.” You keep saying “list checking.” What are you talking about?
- A. List checking refers to the process of comparing grantee lists (those organizations to whom you grant funds) with one terrorist watch list from the U.S. Government – OFACSDN (Office of Foreign Assets Control Specially Designated Nationals). You can read more about this list on the U.S. Treasury website.
Software applications have been developed to facilitate the process of checking names against this list. There are a few different software options available, and we have chosen three in addition to the Bridger Insight Online and Bridger Insight XG products that are sometimes used by organizations with large lists of grantee data to check.
- Q. How is the watch list put together?
- A. The list is compiled by the U.S. Treasury. Unfortunately, no detailed information exists that describes the process for creating and maintaining it.
- Q. Why do I have to document that I list checked? Do I have to keep paper copies or may I keep files on my computer? How long do I have to keep that documentation?
- A. The documents prove that you checked the grantee list and are your legal protection. You can choose to keep electronic copies of the results, but if you do this, you need to make sure that your computer’’s storage drives or network is backed up regularly and that you are able to restore those back-ups. Paper copies should be stored in a safe and organized place so they don’’t get lost or destroyed.
- Q. What if I'’d like to use list-checking software that you haven’’t included in your suggestions?
- A. The list checking applications we suggest are fairly straightforward to use and affordable. As long as the application you choose allows you to fulfill your requirements for checking lists and documenting the results, you are welcome to use whatever works for you.
List-checking and Grants
- Q. What is an open grant?
- A. An ongoing grant. Grants usually have a start and end date. If the end date has passed, and the work is finished, the grant is closed.
- Q. Does list checking apply to re-grants and scholarships?
- A. Yes. When you sign a new grant agreement and issue a new grant payment, you should list check. Likewise, when you give a scholarship, you should list check.
- Q. Do we list check if we pay a third party for conference registration fees for staff from another organization? What about if we support other organizations by reimbursing travel costs, providing meals, and so on when those organizations attend meetings or training? Are all these grants?
- A. Payments for travel, lodging, and tuition (and reimbursement for these purposes) are grants. When you make such payments to or on behalf of third party individuals or organizations using funds, the payments normally would be considered re-grants. Thus, they would ordinarily be subject to the list checking requirement. Under certain circumstances, payments for travel, lodging, and tuition expenses may qualify for an exception to the list checking requirement. If you want to be safe, it’s best to list check. You can also consult your legal advisor for further information.
- Q. Should we check an organization’s official name and its acronym when the acronym is more commonly used?
- A. List check using the full name.
- Q. With individual names, do you enter both first and last names separated by a space?
- A. It depends how your data is arranged. Many data records have first name in one field and last name in another field. In that case, each name is separated by a comma. When the first and last name is in a single field, the two names would not be separated by a comma.
- Q. When you have data in different fields in a spreadsheet why do you choose a comma as a delimiter?
- A. It’s just a data convention. You can use other symbols such as tab, semi-colon, quote comma, pipe, asterisk, or @ sign.
- Q. If we pay one grant in more than one installment do I have to check the grantee each time I pay the different parts of the same grant?
- A. Yes, you should list check every time you make a payment.
- Q. Should I use the individual’s business address or home address?
- A. The home address is preferable for an individual. If you have both, you can use both if you want to be very diligent.
- Q. How frequently do you get hits? Do you know of organizations that actually had any true hits rather than false positives?
- A. Almost everyone will get a hit because there are shared names around the world. However, true positives are quite rare. The more complete and accurate your data is, the fewer hits you will have. Here is an illustration of this: If you search on Orange Co. Volunteers you may get a hit. If you re-enter it as Orange County Volunteers it will not be a hit.
- Q. After checking, the next thing is to confirm. How do I do that?
- A. Confirming that a record is a false positive or a match doesn’t have anything to do with the software application you may be using. You would request a copy of a passport, driver’s license, or other government-issued identification document to confirm that the ID number and birth date does or doesn’t match.
- Q. In case of a hit, how do we check the driver’s license?
- A. You ask for a copy of it.
- Q. How do I document a record that doesn’t match anything on any list?
- A. Print out the .csv list that was checked on a particular date, print out all hits. No hit documentation means that the data was checked and was not on the list.
- Q. If we have a true positive, will that prevent making a grant, or are there exceptions?
- A. Usually, no grants are made to an organization or individual that is a true positive. If you have other questions about this, contact your legal advisor.
- Q. I just finished list checking my entire database (50 organizations). There were no hits at all. How do I show that I checked all the grantees?
- A. A “clean” run does not produce a paper trail. A “clean” list check can be documented by taking print screens from the list-checking process. To capture screen images, click anywhere on the screen, type ctrl-Print Screen. Open a word processing document, click anywhere in that blank document, and type ctrl-V. The image of the active screen should appear in the word processing document. Name and save the document in the normal way.
- Q. I have questions that aren’t in this FAQ. How can I ask them?
- A. Email your questions to jbeckett@techsoupglobal.org.
Additional Resources
- Q. Why are you providing information about “data care”? What does that have to do with list checking?
- A. List checking requires that you have two things in place: a set of data about the organizations to whom you make grants and the ability to compare that data to the information contained on the watch list. Many organizations do not have their data in a secure and accessible state. The point of the data care information is to provide the information necessary to ensure that data is stable and can be used for list checking purposes. Implementing these suggestions across your organization will have broader benefit than just helping you with list checking, so we believe this will be time well spent for many organizations.
- Q. Why are you providing information about healthy and secure computing (HSC)?
- A. HSC helps nonprofits strengthen the security of your information and communications technology. The HSC best practices lead you through the process of caring for and protecting your data and other components of your information technology.
- Q. I have questions that aren’t in this FAQ. How can I ask them?
- A. Email your questions to jbeckett@techsoupglobal.org.
About Bridger Insight Online and Bridger Insight XG
The following are more detailed questions and answers concerning the LexisNexis products Bridger Insight Online and Bridger Insight XG.
If you already have a subscription to BIO or BIXG, you may continue to use them to check the OFAC SDN list. Renewals of BIO subscriptions will continue until you are contacted by your sales representative regarding an upgrade to BIXG should you wish to continue using the Bridger product. The Bridger Client Services site is a good place to find updated documentation, a means to send questions to Tech Support, and access to the most recent training materials. To create a user account you will need the product code, which you can find in Help>About in your Bridger product.
- Q. Do you recommend that we subscribe to a Bridger product?
- A. Bridger applications are excellent products and especially effective when you need to check more than one watch list. If you check only one list rather than multiple lists, your choice of helpful applications has increased. You may find some of them to be less costly or easier to use, so you should investigate them in light of your particular needs. We recommend that you consider the number of names you will check, how frequently you will check those names, and the technology skill level of the staff who will use these applications.
- Q. My organization wants to establish a Bridger account. How do we do that?
- A. In order to sign up for this software, please call 800-869-0751. This number (toll-free in the U.S.) will connect you to a regional representative at LexisNexis, the company that owns the Bridger products. Once the sales representative confirms your subscription, your organization will be set up with a primary administrative username and password. It may take up to seven business days to receive this information, so please plan accordingly. You will be invoiced for the cost of the subscription.
- Q. Can Bridger Insight be accessed by a dial-up connection?
- A. Yes, but it will be slower. The speed will depend on the speed of the connection and the size of the database, so it’s difficult to say exactly how much slower.
- Q. Where can I find more help from LexisNexis, the company that makes the Bridger applications?
- A. Information about Bridger Insight Online and Bridger Insight XG is available from the following sources:
- The Bridger Client Services site is a good place to find updated documentation, a means to send questions to Tech Support, and access to the most recent training materials. To create a user account you will need the product code, which you can find in Help>About in your Bridger product.
- The Technical Support phone numbers are: 800-915-8930 (toll-free in the U.S.) and 406-556-3055. Technical Support is available Monday through Friday from 6 a.m. to 6 p.m. Mountain Time (excluding major U.S. holidays).
- The main public site for LexisNexis.
About patriotAGENT
- Q. Where can I find more information on patriotAGENT?
- A. patriotAGENT is a service of Lyons Commercial Data. You can contact Susan A. Thompson at 800-684-0388 ext. 210 for sales information or go directly to PatriotAGENT.
About ISTwatch Online
- Q. Where can I find more information or subscribe to ISTwatch Online?
- A. To request an account from ISTwatch Online:
- Email Thuy Pham at ThuyPham@intelligentsearch.com; her phone number is 800-287-0412.
- Visit ISTwatchOnline’s website
About WatchDog Pro
- Q. Where can I find more information on WatchDog Pro?
- A.WatchDog Pro is a service provided by Attus Technologies. You can contact Bradley Allen at 888-494-8449 ext. 254 for sales information or go to Attus Technologies.
