What this check is
Review related-party links, shared directors, family ties, vendors and other conflict indicators. It is a structured public-source and adverse-media review for a specific risk review. 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 this risk category, the goal is not to prove misconduct. The goal is to preserve the public-source trail: what was searched, what was found, what appears relevant, what looks like a false positive, and what should be clarified before a decision is made.
When to run it
- A preferred 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 ngo conflict of interest check 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.
- shared directors, related-party vendors, family or ownership links
- undisclosed affiliations that may affect procurement or award decisions
- 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.
- Separate allegations, official findings, court records, donor actions, media claims and social posts into different evidence types.
- Record severity, recency, source reliability, whether the matter is resolved, and whether the same entity or person is confirmed.
- Use local-language terms for fraud, abuse, corruption, exploitation, diversion, terrorism financing, prosecution, audit and investigation.
- Log false positives with the reason: different country, unrelated acronym, similar person name, outdated article or weak identity match.
- Translate or summarize local-language material carefully and preserve the original title, outlet, date and link.
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 PSEA and safeguarding review, public-source checks should sit beside capacity assessment, reporting-channel review, survivor-centered procedures and partner clarification where appropriate.
- For terrorist-financing or aid-diversion risk, FATF guidance is a reminder to keep measures focused and proportionate rather than treating all civil-society activity as high risk.
Field focus for this review
Review public-source related-party links, shared directors, family or ownership connections, vendor relationships and undisclosed interests.
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.
- company and NGO registries showing directors and addresses
- procurement award notices and supplier records
- beneficial ownership records where public
- public biographies, LinkedIn-style profiles and board memberships
- 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
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" "same address"
"DIRECTOR NAME" "COMPANY NAME"
"ORGANIZATION NAME" "related party"
"KEY OFFICIAL" vendor
"BOARD MEMBER" procurement
"REGISTRATION NUMBER" director
"ORGANIZATION NAME" "COUNTRY" "audit"
"ORGANIZATION NAME" "COUNTRY" "investigation"
"ORGANIZATION NAME" "COUNTRY" "fraud" OR "corruption"
"ACRONYM" "Executive Director" "COUNTRY"
What reviewers often miss
- Not searching director names against vendor, supplier and subcontractor names.
- Ignoring repeated addresses, phone numbers, emails or family names across entities.
- Failing to check whether a board member also owns a proposed supplier.
- Treating an apparent link as misconduct before asking for disclosure and recusal records.
- Not saving registry pages before they change.
- 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 |
|---|---|---|---|
| Shared director found | Confirm dates and roles in both entities and ask whether the relationship was disclosed. | Registry records and date accessed. | Escalate if the link affects procurement, grant award or oversight. |
| Same address appears | Check whether it is a common building, registered-agent address or true operational link. | Address records and reviewer note. | Escalate if combined with shared people, phone, email or contracts. |
| Vendor link appears | Check whether the partner can influence the vendor selection or payment. | Procurement source, role notes and disclosure request. | Escalate to procurement and compliance if influence is plausible. |
| Family relationship public | Record only relevant public facts and avoid unnecessary personal details. | Source and relevance note. | Escalate if the relationship intersects with award, hiring, payment or oversight. |
| Undisclosed relation | Ask for conflict disclosure, mitigation and recusal documentation. | Question, response and disclosure documents. | Escalate if response is absent or contradicts public records. |
Realistic review scenarios
| Scenario | Why it matters | How to document it |
|---|---|---|
| Two bidders share a director with the partner organization. | The same person may influence specifications, bids or payments. | Save registry extracts for each entity and escalate to procurement for conflict review. |
| A proposed subcontractor uses the same phone number and address as a key official's company. | Shared contact details can indicate related-party risk. | Check ownership and director records, then ask for disclosure and recusal evidence. |
| A board member appears on a supplier website as a consultant. | The link may be benign, but it must be disclosed if the supplier benefits from the award. | Document the source and ask whether the relationship affects procurement or oversight. |
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 organization or associated key person 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
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.
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.
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.
Related due diligence guides
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.
NGO Safeguarding Due Diligence: Public-Source Review Before SelectionCheck public-source safeguarding and protection concerns before selecting a partner or grantee.
PSEA Partner Due Diligence: Public-Source Checks for Partner ReviewReview public-source signals connected to protection from sexual exploitation and abuse.
NGO Partner Due Diligence Report: What to Check Before SelectionReview a preferred NGO partner before award, agreement signing, onboarding or renewal.
Implementing Partner Due Diligence: Public-Source Checks Before Agreement SigningDocument the public-source review of an implementing partner before funds, responsibilities or program authority are assigned.