Mott USA PATRIOT FAQ

Charles Stewart Mott Foundation re-granting compliance project

FREQUENTLY ASKED QUESTIONS

 Q.  Why is Mott requiring USA PATRIOT Act compliance?

A.  Mott has provided information for its re-granting grantees on the Mott website at http://toolbox.mott.org. If you have additional questions about Mott’s policy or decisions, please contact your program officer.

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:

• Handbook on Counter-Terrorism Measures: What U.S. Nonprofits and Grantmakers Need to Know (.pdf)
• Legal Dimensions of International Grantmaking > Second Quarter 2004 > Grantmaking in an Age of Terrorism (.pdf)

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.  Why are you talking to us about “Data Care”? What does that have to do with the project?

A.  List-checking requires that you have two things in place: A set of data about the organizations to whom you are re-granting Mott monies; and the ability to compare that data to the information contained on three main watch lists. 

According to the needs assessment CompuMentor conducted with funds from Mott, many organizations do not have their data in a secure and accessible state. The point of the Data Care training and assistance 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.  You’ve talked about the needs assessment. I think I remember seeing a survey, but I didn’t reply. So where do I fit in?

A.  If you didn’t respond to the survey during the needs assessment, we will be contacting you or your Mott program officer for specific information to help us better understand your needs and tailor our assistance to meet those needs. If you’d like to complete the survey at this time, please contact us.

 Q.  What if I’d like to use different list-checking software?

A.  Mott is recommending and supporting the use of a specific application called Bridger Insight Web v6.0. If you would like to use a different application for list-checking, please let us know so that this can be cleared with the Mott Foundation program officers.

 Please know that Mott is covering the first year subscription cost for the chosen list-checking software (Bridger Insight) and may not provide financial support for other list-checking applications.

 Q.  List-checking. You keep saying list-checking. What are you talking about?

A.  List-checking refers to the process of comparing your grantee lists (those organizations to whom you are re-granting Mott monies) with terrorist watch lists from the US government, European Union and the United Nations.

 Software applications have been developed to facilitate this process. There are a few different software options available, but Mott has chosen to recommend the web-based version of Bridger Insight to their grantees.

 Q.  How are those lists put together?

A.  These lists are put together by various government entities. They are based on information made available to those governments or organizations. Unfortunately, there is no detailed information that describes the process for creating these lists.

 Q.  Does that mean we can’t write checks to anyone who is on the lists?

A.  Compliance is a matter of behaviors – not software. To this end, Mott has provided a series of documents that describe the human procedures that need to be put in place to ensure compliance. If you have a match during list checking, there are steps that you need to follow to ensure that you are documenting a match and the process you used to determine whether or not to still provide funding to that organization. Mott has provided an explanation and guidelines for this process at http://toolbox.mott.org.

 Q.  Will the technology assistance providers tell Mott whether or not I’m following the rules?

A.  CompuMentor, NPower and all other technology assistance partners are here to help you build the capacity you need to meet the list-checking requirements. Along the way, we hope to provide you with the capacity to better care for your data. We are not here to let Mott know whether or not you are using the list-checking software – that’s between you and the Mott Foundation via reporting requirements. We will simply report on whether or not you’ve attended trainings, the results of your direct assistance visit, and the evaluation of the technical assistance we are providing.

 Q.  Does my organization have to participate in the technical assistance?

A:  If you do not want to participate in the technical assistance that CompuMentor, NPower, and other partners are providing, please talk with your Mott Program Officer. We applaud Mott for putting resources behind building the capacity of the organizations they fund to meet this new requirement, so we encourage you to take advantage of this free assistance. 

 Q.  My organization is already using the list-checking software. Why do I need hands-on consulting services?

A:  A consultant can still help you by documenting your list-checking process. Having a document to follow can help if you only re-grant Mott funds once or twice a year, and therefore rarely use the list-checking process. It can also help train new staff who may take over from a staff member who has left the organization or moved to a different job within the organization. Having the documentation can help keep the process error free and efficient.

 Q.  How do I learn more about the partners involved?

A.  Please visit the project web space at http://www.techsoup.org/mott to find information about all participating technology assistance providers.