What this check is
Document the public-source review of an implementing partner before funds, responsibilities or program authority are assigned. It is a structured public-source and adverse-media review for a specific partner selection. The work focuses on the organization, known or discoverable key people, former names, local-language variants and risk terms that may matter to the decision.
For partner selection, the goal is to create a decision file that shows the team reviewed the preferred organization and associated key people before award, signing, onboarding or renewal.
When to run it
- An implementing partner has been identified as the preferred option.
- The team is preparing an award, grant agreement, contract, consortium role, onboarding step or periodic renewal.
- A donor file, procurement file, partner file or internal approval memo needs a documented public-source review.
- Names, acronyms, former names, key officials or local-language variants should be checked before signing.
What risk categories it covers
A useful implementing partner due diligence should be broader than a name search. IntegrityFile reports organize public-source signals into review categories so the file shows what was checked and why it mattered.
- adverse media, public complaints and reputation signals
- identity, governance, leadership and official registration indicators
- fraud, corruption and misuse of funds
- safeguarding and PSEA concerns
- aid diversion and restricted-party exposure
- political exposure and neutrality concerns
- conflicts of interest and related-party links
- rebranding, former names and identity continuity
- governance, registration and leadership concerns
- legal, regulatory and court-record signals
Practical checks to run
These are the checks that make the file useful to a real reviewer rather than just a generic screening note.
- Capture the exact legal name, English name, acronym, original-language name, former names and registration number if available.
- Search the organization plus country, city, founder, executive director, board chair and common acronym variants.
- Record whether leadership on the website matches registry, donor, annual report and news references.
- Look for continuity signals: same address, same directors, same logo, same projects or same donors under a prior name.
- Save the source URL, publication date, access date, language searched and a short note explaining why the source matters.
What public sources may be reviewed
Source availability varies by country, entity type and language. The review should record the sources searched, the search terms used, and any limits in public coverage.
- official organization, company, charity or NGO registries where available
- beneficial ownership, director and officer records where public
- organization websites, annual reports, project pages and leadership pages
- donor, audit, inspector-general, debarment and procurement records
- government, regulator, court and legal records where accessible
- media archives, local-language searches and public web footprint indicators
Useful source notes
These reference points help reviewers understand what to capture, how to search, and why a name-only result is not enough.
- UN Security Council sanctions are organized by regime, so a possible match should be reviewed against the specific listing basis and measures, not just the name.
- OFAC search results include program codes; those codes are part of the review because different sanctions programs may imply different treatment.
- World Bank debarment search works better with partial names and without accents or generic company words such as Limited, Corp. or Ltd.
- For pre-award partner review, USAID OIG findings show why it matters to document past performance, organizational capacity, financial capacity and required certifications.
- For local partners, original-language names and leadership titles often produce materially different search results from English-only queries.
Field focus for this review
Confirm the identity of the partner, then document public-source signals that are relevant to the proposed partner selection.
Do not turn a public-source signal into a conclusion. The file should show the source, identity match, relevance analysis, false-positive reasoning where applicable, and any follow-up or escalation taken.
- official registry records for legal name, status, address and officers
- organization website, annual report, donor pages and leadership biographies
- local-language media and civil-society references using spelling variants
- debarment, exclusion, sanctions and donor records where relevant to the file
Search terms to try
Replace the placeholders with the legal name, acronym, former name, original-language name, country, project location and known key officials. Keep the exact search terms in the file so the review can be repeated later.
"ORGANIZATION NAME" "COUNTRY" "audit"
"ORGANIZATION NAME" "COUNTRY" "investigation"
"ORGANIZATION NAME" "COUNTRY" "fraud" OR "corruption"
"ACRONYM" "Executive Director" "COUNTRY"
"FORMER NAME" "ORGANIZATION NAME"
"ORIGINAL LANGUAGE NAME" "COUNTRY"
What reviewers often miss
- Only searching the English name and missing the original-language legal name.
- Treating a same-name article as relevant before checking country, address, registration number or official title.
- Failing to search former names, abbreviations and local transliterations.
- Not recording the search term and access date, which makes the file hard to defend later.
- Saving only the conclusion instead of the source link, date, identity match and reviewer reasoning.
What to do when a signal appears
A useful file records the reviewer response, not only the search result. Use the table as a practical starting point and adapt it to internal policy.
| Situation | Reviewer action | Evidence to keep | Escalate when |
|---|---|---|---|
| Weak identity match | Compare country, city, address, registration number, officers and dates before treating it as relevant. | Screenshot or PDF of the result, search term used, and identity fields checked. | Escalate only if two or more identifiers match or the source is official. |
| Relevant adverse-media article | Separate allegation from confirmed finding and check whether the matter is current, resolved or disputed. | Article URL, publisher, publication date, translated title if needed, and reviewer note. | Escalate if the allegation concerns misuse of funds, safeguarding, aid diversion, criminal conduct or donor funds. |
| Local-language result | Preserve original title and link, then translate or summarize the relevant part without changing the meaning. | Original wording, machine or human translation note, URL and date accessed. | Escalate if translation points to serious misconduct or an official proceeding. |
| Unclear former-name connection | Look for continuity through address, directors, logo, project history, donor references or registry documents. | Former-name source and continuity indicators reviewed. | Escalate if the predecessor entity has unresolved serious findings and continuity is credible. |
| Partner clarification needed | Ask targeted questions rather than sending broad accusations or raw search results. | Question sent, response received, and reviewer assessment of whether it addresses the signal. | Escalate if the response is incomplete, inconsistent with public records or raises new issues. |
Realistic review scenarios
| Scenario | Why it matters | How to document it |
|---|---|---|
| A preferred partner has a common acronym that matches an unrelated group in another country. | The file could incorrectly treat an unrelated adverse article as relevant. | Log the result as a false positive only after checking country, full legal name, leadership and registration details. |
| A search finds an old article about a founder, but the article does not say whether the founder still has a role. | The risk may be stale, unrelated or still relevant depending on current authority. | Check current board and leadership sources, then record whether the person remains a key official. |
| A donor page lists a different organization name than the registry. | The entity may have rebranded, merged, translated its name or used an informal program name. | Search both names and save the source trail explaining the relationship. |
File-ready wording examples
Use cautious language. The wording should describe the public-source review and next step, not make the final selection decision.
No relevant findingsPublic-source searches were completed for the legal name, acronym, country, available local-language variants and named key officials. No relevant adverse public-source signals were identified within the scope of this review.
Clarification neededA public-source signal was identified that may relate to the organization under review. The reviewer has not treated it as a conclusion and has requested clarification on identity, context, current status and any remedial action.
False positiveA similar-name result was reviewed and dismissed because the available identifiers do not match the organization, country, address, role or time period in scope. The result has been logged as a false positive.
EscalationA potentially relevant public-source signal requires internal review before the file is finalized. The source, identity-match notes, reviewer assessment and recommended clarification questions have been saved in the file.
What the report includes
- organization name, country, acronym, legal or original-language name and known aliases
- known key officials, or a best-efforts public-source identification of relevant officials
- risk category summary with source-linked findings for human review
- search terms, source table, dates reviewed and evidence notes
- false positive log for unrelated names, outdated results or weak matches
- reviewer fields for relevance, clarification, escalation and final file notes
Evidence to capture in the file
- source title, publisher, URL and date accessed
- exact search term used, including language and spelling variant
- identity match notes: country, address, registration number, official title, date of birth if lawfully available
- finding type: relevant, irrelevant, false positive, needs clarification or escalation required
- reviewer note explaining why the item was included or dismissed
- follow-up question for the partner, vendor, grantee or internal reviewer
Common false positives to watch for
- same acronym used by an unrelated organization in another country
- same person name but different title, city, employer or date range
- old legal dispute involving a predecessor entity with no confirmed continuity
- media article about a sector-wide issue that does not identify the organization under review
- sanctions or debarment search result with weak fuzzy-match confidence and no matching identifiers
What it does not replace
This check does not replace sanctions screening, legal review, safeguarding investigation, procurement approval, vendor eligibility checks, finance review, donor clearance or any required internal decision process. It supports the public-source due diligence step by creating a documented record for human review.
Sample follow-up questions
- Does the public-source record confirm this is the same partner under review?
- Are there former names, aliases, directors, signatories or related entities that should be searched separately?
- Are any findings current, serious and relevant to the proposed decision, or are they historical or likely unrelated?
- Should the organization be asked for clarification before approval, award or escalation?
- Do any findings trigger internal safeguarding, procurement, legal, donor, finance or management review requirements?
Reference sources for reviewers
UN implementing partner PSEA resource packageIncludes self-assessment, scoring, capacity-strengthening and monitoring materials, plus sample communications and partner guidance in multiple languages.
FATF Recommendation 8 best practices for non-profit organisationsEmphasizes focused, proportionate, risk-based measures for the subset of NPOs that fall within FATF's definition, while avoiding undue disruption of legitimate activity.
USAID OIG pre-award risk management auditThe 2024 audit is useful because it names practical pre-award risk areas: past performance, organizational and financial capacity, documentation of required reviews, certifications and enterprise risk management.
OFAC Sanctions List SearchUses approximate string matching and program codes. A possible hit should be reviewed for identity, program, identifiers and relevance; the tool is not a substitute for due diligence.
UN Security Council Consolidated ListProvides the current Consolidated List in XML, HTML and PDF. At the reviewed version dated 21 May 2026, the page listed 730 individuals and 272 entities or groups.
Related due diligence guides
NGO Partner Due Diligence Report: What to Check Before SelectionReview a preferred NGO partner before award, agreement signing, onboarding or renewal.
Partner Selection Due Diligence: Building a File Before ApprovalCreate a structured partner selection file that supports review, clarification and escalation.
Pre-Award Partner Due Diligence for NGOs and Grant TeamsRun public-source checks before award, grant agreement, subcontract or consortium approval.
NGO Partner Review Checklist for Selection-Stage Due DiligenceA practical checklist for documenting partner identity, governance, reputation and risk signals.
Adverse Media Check for NGOs: What Public Sources Can ShowReview negative media, local-language reporting, public complaints and reputation signals without treating allegations as conclusions.
NGO Fraud Risk Due Diligence: Public-Source Signals to DocumentDocument public allegations and records related to fraud, misuse of funds, procurement concerns and integrity issues.