Published Risk Taxonomy

What we score. What we refuse to score.

Every signal on this platform must have a financial-crime nexus — a stated connection to fraud, diversion, sanctions evasion, or misrepresentation. This page publishes the complete taxonomy: the six scored signal families, the categories that are explicitly excluded from scoring, the fixed treatment each adjudication status receives, and the appeal right that attaches to every adverse routing. If a category is not listed as scored here, it is not scored.

Advisory only — not a guarantee. The enterprise makes the final decision.

The principle

Route to review — never auto-reject

No signal in this taxonomy rejects an application or a grant on its own. Every finding routes the matter to a human reviewer with its evidence attached. The two exceptions — a revoked IRS exemption and a confirmed OFAC SDN match — are hard legal bars on disbursement, not model judgments, and both are disclosed in the treatment table below along with the regulatory workflow they trigger.

Uncertainty always resolves toward more human scrutiny, never toward automated denial: an unknown can block a streamlined fast path, but it can never fabricate an adverse signal.

Scored — six signal families

Everything the platform scores belongs to one of these families, and each family answers one financial-integrity question. The full factor weights and thresholds are published on the methodology page.

01  Identity & registration
Is this organization what it says it is?

EIN validity · IRS 501(c)(3) status and Pub 78 / BMF listing · auto-revocation and reinstatement history · state registration and foreign-registry cross-checks · name/EIN conflicts between authoritative sources

02  Sanctions & exclusions
Is any party legally barred from receiving funds?

OFAC SDN and Non-SDN Consolidated screening (org, officers, advisors) · SAM.gov federal exclusions · HHS OIG LEIE · consolidated open-sanctions sources

03  Financial shape (Form 990 forensics)
Do the reported finances carry known fraud signatures?

Conduit / pass-through ratios · non-cash (gifts-in-kind) majority revenue · year-over-year revenue step-changes · grant fan-out anomalies · professional-fundraiser dependence · filing gaps

04  Network & entity graph
Is this applicant structurally entangled with other applicants?

Shared verified attributes (addresses, bank identity, officers) across applicants · officer/advisor overlap with recipients · ring and phoenix-pattern detection

05  Payments & banking
Is the money going where the record says it goes?

Banking-detail changes shortly before a payment decision · payee/recipient mismatch · payment velocity and volume anomalies · rail-appropriateness review

06  Applicant behavior & provenance
Was the application made honestly, from where it claims?

VPN / geolocation mismatch during intake · document tampering and forgery checks · credential exposure (dark-web) findings · web-presence corroboration

Excluded from scoring — by policy

Politically contested and ideological categories are excluded from every score, tier, and automated decision — by policy, not by omission. Publishing the exclusion makes it enforceable: if a signal cannot be tied to one of the six families above, it does not enter the model.

Cause area & mission

What a charity works on — religion, reproductive health, firearms, immigration, climate, animal rights, or any other cause — is never a risk input. NTEE cause codes are used for identification, not for scoring.

Religious affiliation

Faith-based status, denomination, or religious practice carries zero weight in any signal family.

Political & advocacy positions

Lawful advocacy, lobbying within legal limits, and the political leanings of an organization or its officers are not scored. Only conduct with a financial-crime nexus is.

Ideological controversy

Being criticized, boycotted, or "controversial" is not a signal. Adverse media enters the file only when it alleges financial misconduct — and even then it is note-only (see the treatment table below).

Officers’ lawful activity

Board members’ and officers’ lawful political donations, affiliations, and speech are never inputs. People screening is limited to sanctions, exclusions, and documented financial-crime exposure.

Donor identity & intent

Who recommends a grant, and why, is not scored against the recipient. Donor-control signals exist only to protect against private-benefit rule violations, a defined legal standard.

Fixed treatment — the six-tier adjudication ladder

Each adjudication status maps to exactly one treatment. The mapping is fixed and published — a reviewer can depart from it only in the safer direction (more scrutiny), never toward automated denial.

Block
IRS exemption revoked / confirmed OFAC SDN match

The only hard stops on the platform, and both are legal requirements rather than model judgments. The application is rejected, so the grant is never cleared for payment; a sanctions-driven decline can also carry a 10-business-day OFAC reporting duty under 31 CFR §501.604 (see below).

Escalate
Confirmed federal exclusion / debarment (SAM.gov, LEIE)

Routed to senior review. Never auto-rejected — the reviewer confirms identity (exclusion lists are name-keyed) before any adverse action.

Hold
Potential (fuzzy) sanctions or exclusion match — unadjudicated

A human adjudicates the match before anything else happens. Homonym collision is common on name-keyed lists; a fuzzy hit means "a person must look", never "disqualified".

Hold
Regulatory or enforcement action on record (state AG, FTC, IRS penalty)

Documented enforcement history is weighed by a reviewer in context — age, resolution, and relevance — never applied as an automatic penalty.

Enhanced diligence
Reinstated after revocation / filing gaps / limited track record

Moves the organization to a higher due-diligence tier (more evidence, more corroboration). A scrutiny level, not an adverse decision.

Note only
Adverse media

Recorded beside the file for reviewer context. Media coverage never moves a decision, score, or tier by itself — it can only prompt a human to verify primary sources.

When a confirmed sanctions match leads you to reject or block a grant, federal regulation (31 CFR §501.604) requires the rejected or blocked transaction to be reported to the U.S. Treasury’s Office of Foreign Assets Control within 10 business days. DAF Connect does not send or hold grant funds: it records the rejection and preserves the screening evidence with the record. A report item that tracks the filing deadline is built but not yet opened automatically.

Your rights

The appeal right

Every adverse routing — a hold, an escalation, an enhanced-diligence tier, or a block — carries an appeal right:

  1. You are told which signal family produced the routing, in plain language, with the evidence the reviewer will see.
  2. A human reviewer — never a model — makes the final decision, and a different reviewer hears the appeal.
  3. You may submit corrections and supporting evidence (a reinstatement letter, a bank confirmation, proof of a name collision) through the appeal form in your portal, and the file is re-adjudicated against this published taxonomy.
  4. For sanctions blocks, the legal bar is OFAC’s, not ours: we identify the specific list and entry so the counterparty can pursue OFAC’s own administrative remedies (reconsideration or a specific license), and we re-screen immediately on request once a delisting or license is in hand.

Appeals are tracked as first-class records with their own audit trail, and appeal outcomes feed the model-governance review published on the methodology page.

A published line, not a moving target.