Version: 2026-07-08 draft.
Article I. EducateONE Organizational Policies
Chapter 12. Finance, Accounting, Internal Controls, Banking, and Gifts
EducateONE Organizational Policy § 12.9.00. International Restricted-Party and Cross-Border Compliance Policy.
(a) Purpose of Policy
(1) In order to advance EducateONE’s charitable, educational, and institutional purposes through lawful international activity, EducateONE may work with foreign persons, foreign organizations, foreign schools, foreign vendors, foreign partners, foreign intermediaries, and other cross-border participants when such activity is consistent with EducateONE’s mission and legal responsibilities.
(2) This policy establishes international screening, review, escalation, and recordkeeping requirements intended to prevent EducateONE from engaging in prohibited, restricted, unauthorized, or unresolved cross-border transactions.
(3) This policy supplements EducateONE’s generally applicable policies on student assistance, conflicts of interest, financial controls, records retention, contracts, gifts, grants, and tax-exempt compliance, and is intended to address compliance issues that arise specifically because a person, organization, transaction, activity, payment, service, technology, or benefit is foreign or cross-border.
(4) This policy is intended to reduce the risk that EducateONE funds, property, services, technology, access, credentials, platforms, educational activities, charitable assistance, or other things of value are diverted to or used for terrorism, terrorist financing, money laundering, sanctions evasion, corruption, prohibited end uses, or other unlawful purposes.
(5) Because sanctions, anti-money-laundering, export-control, anti-terrorism, foreign-payment, and related laws, regulations, lists, licenses, general licenses, and government guidance may change, it is the overriding policy of EducateONE to comply with current law even if this policy has not yet been updated to reflect the change.
(6) The Executive Director, Compliance Officer, Treasurer, Board Chair, legal counsel, or another authorized person shall inform the Board of Directors when such person becomes aware that a change in law, regulation, official list, license, general license, government guidance, enforcement position, or institutional activity requires or reasonably warrants an update to this policy.
(7) EducateONE’s review under this policy shall be administered with a presumption that persons and organizations are acting lawfully and in good faith unless facts indicate otherwise.
(8) A person administering or applying this policy shall remain observant of red flags, unusual facts, inconsistent information, or unresolved concerns that may indicate a prohibited, restricted, unauthorized, misleading, or unlawful transaction, even when the specific issue is not expressly listed in this policy.
(9) EducateONE shall not ignore a red flag, unusual fact, inconsistent information, or unresolved concern merely because it is not specifically named in this policy.
(b) Stage I Baseline International Intake.
(1) EducateONE shall complete baseline international intake before approving, funding, paying, contracting with, partnering with, providing services to, receiving services from, or otherwise working with a foreign person, foreign organization, foreign school, foreign vendor, foreign partner, foreign intermediary, foreign bank, foreign recipient, or other foreign or cross-border participant in connection with a covered international activity.
(2) Stage I intake shall identify, to the extent reasonably available:
(A) the legal name, trade name, known aliases, alternate spellings, foreign-language spellings, and transliterations of the foreign person, organization, school, vendor, partner, intermediary, bank, recipient, or other covered party;
(B) the address, country, region, and location connected to the person, organization, transaction, activity, payment, service, technology, or benefit;
(C) the principal contacts and known officers, directors, owners, controllers, managers, responsible persons, payment controllers, intermediaries, or related parties, when reasonably available;
(D) the activity, payment, service, technology, access, property, equipment, assistance, or other thing of value that EducateONE will provide, receive, fund, transfer, authorize, or support;
(E) the person, organization, school, group, community, individual, or other end recipient that will receive, control, use, distribute, or benefit from the funds, goods, services, technology, access, property, equipment, assistance, or other thing of value;
(F) the payment route, bank, correspondent bank, payment processor, payment intermediary, cryptocurrency transfer, cash transfer, informal value-transfer system, or other financial channel, when money or other value will be transferred;
(G) whether the activity involves a foreign government body, foreign ministry, foreign public school, foreign public university, foreign state-owned entity, foreign political party, foreign candidate, foreign public official, or person acting in an official capacity for a foreign government or public institution;
(H) whether the activity involves software, source code, technical data, controlled technology, artificial-intelligence tools, specialized equipment, platform access, encryption items, or technical assistance provided to, released to, accessed by, shipped to, or used by a foreign person or from outside the United States; and
(I) any other information reasonably necessary to conduct Stage II required official screening or determine whether Stage IV conditional international review is required.
(3) EducateONE shall not treat Stage I intake as complete if the information collected is insufficient to conduct required official screening or determine whether the covered international activity must be held, denied, conditionally reviewed, or escalated under this policy.
(c) Stage II Required Official Screening.
(1) EducateONE shall complete Stage II required official screening after Stage I intake and before approving, funding, paying, contracting with, partnering with, providing services to, receiving services from, or otherwise proceeding with a covered international activity.
(2) Stage II required official screening shall include review of:
(A) OFAC Sanctions Programs and Country Information, to determine whether the country, region, government, sector, payment route, service, transaction, or activity is subject to a sanctions program, restriction, license requirement, or other country-based or program-based limitation;
(B) the U.S. Consolidated Screening List, to determine whether the person, organization, school, vendor, partner, intermediary, bank, recipient, principal, officer, owner, controller, known alias, alternate spelling, or related party appears on a consolidated United States restricted-party list; and
(C) OFAC Sanctions List Search, to determine whether the person, organization, school, vendor, partner, intermediary, bank, recipient, principal, officer, owner, controller, known alias, alternate spelling, or related party appears on an OFAC sanctions list or presents a possible OFAC sanctions match.
(3) Stage II required official screening shall be completed using the identifying information obtained through Stage I intake and any additional identifying information reasonably available before screening is completed.
(4) No covered international activity is exempt from Stage II required official screening solely because the amount, value, duration, frequency, educational benefit, charitable purpose, perceived risk, or expected benefit is small.
(d) Stage III Initial Determination.
(1) After Stage I intake and Stage II required official screening, EducateONE shall make an initial determination before proceeding with the covered international activity.
(2) The initial determination shall classify the covered international activity as one or more of the following:
(A) cleared for ordinary approval review;
(B) subject to Stage IV conditional international review;
(C) subject to Stage V escalation and legal authorization review;
(D) held pending additional information;
(E) denied because the activity is prohibited, restricted, unauthorized, or otherwise not approved under this policy; or
(F) withdrawn or discontinued.
(3) EducateONE shall not proceed with a covered international activity if Stage I intake or Stage II required official screening identifies:
(A) a confirmed restricted-party match;
(B) an unresolved possible restricted-party match;
(C) a restricted country, region, government, sector, payment route, service, transaction, or activity;
(D) a possible sanctions-program restriction;
(E) insufficient identifying information to complete required official screening;
(F) incomplete, inconsistent, unverifiable, or materially different identifying information;
(G) a condition requiring Stage IV conditional international review; or
(H) any other unresolved issue indicating that the activity may be prohibited, restricted, unauthorized, or legally uncertain.
(4) A covered international activity described in paragraph (3) may proceed only after the issue has been resolved through Stage IV conditional international review, Stage V escalation and legal authorization review, written legal determination, applicable government authorization, applicable license, applicable general license, or other approval authorized under this policy.
(e) Stage IV Conditional International Review.
(1) EducateONE shall complete Stage IV conditional international review only when one or more of the specific conditions in this subdivision applies.
(2) Restricted-party ownership and control review.
(A) If ownership, control, beneficial ownership, fiscal sponsorship, responsible persons, officers, directors, principals, managers, payment controllers, intermediaries, banks, or related parties must be identified to complete Stage II required official screening, resolve a possible match, determine whether a restricted party owns or controls a covered party, or determine whether funds, services, technology, access, property, equipment, or benefits may reach a restricted party, EducateONE shall complete restricted-party ownership and control review.
(B) The review shall be used to determine which additional persons, entities, aliases, addresses, banks, intermediaries, or related parties must be screened under Stage II or reviewed under this policy.
(3) Foreign-government and improper-payment review.
(A) If the covered international activity involves a foreign government body, foreign ministry, foreign public school, foreign public university, foreign state-owned entity, foreign political party, foreign candidate, foreign public official, or person acting in an official capacity for a foreign government or public institution, EducateONE shall complete a foreign-government and improper-payment review.
(B) The review shall occur before EducateONE provides money, gifts, travel, meals, honoraria, stipends, services, equipment, benefits, or anything else of value to or for the benefit of the person, entity, institution, or official capacity involved.
(4) Export-control review.
(A) If the covered international activity involves software, source code, technical data, controlled technology, artificial-intelligence tools, specialized equipment, platform access, encryption items, or technical assistance provided to, released to, accessed by, shipped to, or used by a foreign person or from outside the United States, EducateONE shall complete an export-control review.
(B) The review shall occur before access, transfer, release, shipment, service, instruction, technical assistance, or other use is provided.
(5) Payment-route review.
(A) If the covered international activity involves a foreign bank, correspondent bank, payment processor, cryptocurrency transfer, cash transfer, informal value-transfer system, payment intermediary, third-party payee, mismatched payment instruction, or payment route outside ordinary United States banking channels, EducateONE shall complete a payment-route review.
(B) The review shall occur before funds, assets, services, equipment, or other things of value are transferred.
(6) End-recipient and end-use review.
(A) If EducateONE will provide funds, goods, equipment, services, technology, access, or other assistance to one party for use by, transfer to, control by, or benefit of another organization, school, group, community, individual, or end recipient outside the United States, EducateONE shall complete an end-recipient and end-use review.
(B) The review shall be sufficient to identify, to the extent reasonably possible, who will receive, control, use, distribute, or benefit from the funds, goods, equipment, services, technology, access, or assistance.
(7) Identity-resolution review.
(A) If identifying information for a covered party is incomplete, inconsistent, unverifiable, materially different from the information used in Stage II required official screening, or insufficient to resolve a possible match, EducateONE shall complete an identity-resolution review.
(B) EducateONE shall not treat Stage II required official screening as cleared until the identity issue has been resolved or escalated under this policy.
(8) EducateONE shall not treat Stage IV conditional international review as complete until each applicable Stage IV condition has been reviewed and documented.
(9) EducateONE shall not proceed with a covered international activity if Stage IV conditional international review identifies:
(A) a confirmed prohibition;
(B) an unresolved possible prohibition;
(C) an unresolved legal restriction;
(D) an unresolved restricted-party ownership or control issue;
(E) an unresolved foreign-government, foreign-official, or improper-payment issue;
(F) an unresolved export-control issue;
(G) an unresolved payment-route issue;
(H) an unresolved end-recipient or end-use issue;
(I) an unresolved identity issue; or
(J) insufficient information to determine whether the covered international activity may proceed.
(10) A covered international activity described in paragraph (9) may proceed only after the issue has been resolved through Stage V escalation and legal authorization review, written legal determination, applicable government authorization, applicable license, applicable general license, or other approval authorized under this policy.
(f) Stage V Escalation and Legal Authorization Review.
(1) EducateONE shall complete Stage V escalation and legal authorization review when a covered international activity presents a confirmed prohibition, unresolved possible prohibition, unresolved legal restriction, unresolved restricted-party match, unresolved sanctions-program issue, unresolved export-control issue, unresolved foreign-government or improper-payment issue, unresolved payment-route issue, unresolved end-recipient or end-use issue, unresolved identity issue, or other unresolved issue that may make the activity prohibited, restricted, unauthorized, or legally uncertain.
(2) A covered international activity requiring Stage V review shall not proceed unless the issue has been resolved through one or more of the following:
(A) written legal determination;
(B) applicable government authorization;
(C) applicable license;
(D) applicable general license;
(E) written determination that the possible match or possible restriction is a false positive;
(F) written determination that the activity has been modified so that the restriction no longer applies;
(G) written approval by the Board of Directors, Executive Director, Compliance Officer, Treasurer, Board Chair, or other person authorized by EducateONE; or
(H) other written resolution authorized under this policy.
(3) EducateONE may deny, discontinue, suspend, modify, or decline to proceed with any covered international activity requiring Stage V review.
(4) Nothing in this policy requires EducateONE to seek a government license, request legal review, continue review of a proposed activity, or proceed with a covered international activity that EducateONE determines should be denied, discontinued, suspended, modified, or declined.
