Compliance Review Overview

Each organizational and individual grant goes through compliance review.

This is a crucial function for both New York and Budapest grants management.

There may be a need to request additional clarification about the project and the grantee.

Grants Management determines how a grant is set up based on:

Where the organization is registered and based

The legal or tax status of the organization (whether it is a non-U.S. organization, a 501(c)(3) public charity, private foundation, supporting organization, 501(c)(4) organization, for-profit entity, etc.)

The amount of the grant.

Slight differences between NY and BP review:

The selection of funding sources differs in New York and Budapest.

U.S. vs. non-U.S. sourcing criteria varies between New York and Budapest

Grants Officer’s Responsibility:

Grants Officers are responsible for reviewing a proposal record and its related records in Foundation Connect, after those are entered by program staff.

The Pre-Compliance Checklist button on a proposal record helps Grants Officers identity missing data.

The Compliance Review Checklist (see appendix ) guides Grants Officers through the Compliance Review process, detailed below.


Agnes Almadi

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Joe Behaylo

Can we write about how issue escalation is handled during CR? Might cover the following points:
1. There should be adequate training for GOs to answer almost all compliance questions that arise in grantmaking.
2. GOs should look for answers within the team before escalating to a lawyer.
3. We should escalate to lawyers when a scenario or fact pattern is unprecedented or we don’t have a consistent pattern of how to handle a particular scenario.
4. In BP, if you don’t have access to lawyers for certain scenarios, minimize escalation to legal specialists by building collective expertise within GM (including requesting associated training).
5. GOs should go to lawyers summarizing the case and making a recommendation – not just forwarding a long email thread and asking for a solution.
6. If there is likely to be a difference of opinion (or much back and forth), take the program off the communication and circle back when you have an answer. Definitely if there is uncertainty about referring a proposal between offices.
7. Likewise, if something is going to be contentious, try for a call or a meeting instead of generating email churn. Or escalate to regular meetings that you Kriszta and Jenny have with lawyers.
8. Track all proposals escalated to legal review and share response times and data patterns with Legal.

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