Donor Vetting Report
How a 250-credit Donor Vetting Report is produced. The frameworks we adopt, the prospect-research ethics floor we never cross, and the corrections process if we get something wrong.
Overview
A Donor Vetting Report is a paginated, twelve-section due-diligence document on one high-net-worth prospect being considered for major-gift cultivation by a nonprofit, foundation, or corporate-giving office. It is generated on demand from the prospect's public wealth-source profile, philanthropic history, regulatory record, family-foundation 990 filings, peer coverage, and the subject's own enriched profile. It takes three to five minutes to produce, costs 50 credits (about $20 USD), and is delivered as a shareable HTML report with a printable PDF view.
It is intended for a university endowment officer evaluating a naming-gift prospect, a hospital foundation director vetting a major-gift cultivation lead, a museum development office assessing a board-prospect with capacity, or a F500 corporate-giving lead vetting a strategic-philanthropy partnership.
The report is not a verdict on the prospect. It is a structured presentation of the public record for the gift-acceptance committee to evaluate themselves against their institution's risk tolerance. Reputational-risk thresholds vary by institution; this report flags signals at calibrated tiers, and the gift-acceptance decision is yours.
The Five Frameworks We Adopt
MentionFox / Verifierce Donor Vetting Reports align with five published standards drawn from the U.S. intelligence community, the prospect-research profession, anti-money-laundering compliance, and U.K. defence intelligence.
ICD 203 — Analytic Standards (Office of the Director of National Intelligence)
The U.S. Intelligence Community's Directive 203 defines nine tradecraft standards: properly described sources, proper expression of uncertainty, distinction between intelligence and assumptions, incorporation of alternative analysis, judgement of consequences, customer-relevant focus, logical argumentation, accurate reflection of source content, and clear language. We treat these as binding for every Donor Vetting Report.
CASE Prospect-Research Ethics
The Council for Advancement and Support of Education (CASE) publishes ethics guidelines for prospect research that govern how nonprofit development offices may legitimately gather and use information about prospective donors. Core principles: confidentiality of research findings within the institution, proportional research depth (capacity-matched, not invasive), respect for prospect privacy where the public record does not extend, prohibition on pretext gathering or social-engineering data collection. We treat the CASE principles as the ethics floor for every Donor Vetting Report — the report relies entirely on the public record and never on personal-information dimensions where the prospect has not chosen to make information public.
APRA Methodology Standards
The Association of Prospect Researchers for Advancement (Apra) publishes professional methodology standards for prospect research: source documentation, capacity-rating frameworks, philanthropic-history compilation, public-record limits, peer-research-team review, gift-acceptance-committee handoff. Our 12-section structure mirrors the standard Apra prospect profile: capacity, inclination, mission alignment, family circle, board history, reputational risk, plus references-and-citations audit trail.
AML/KYC — Wealth Source Integrity
Anti-money-laundering and know-your-customer compliance frameworks (Bank Secrecy Act, FinCEN guidance, FATF Recommendations, EU AMLD5/6) require institutions to evaluate the integrity of major financial counterparties' wealth sources. Section 6 (Wealth Source Integrity) of every Donor Vetting Report applies these frameworks: how was the wealth acquired, are the source industries / source entities subject to sanctions or enforcement, are there controversial-industry signals (weapons, opioid pharma, surveillance tech, sanctions-exposed commodities, gambling)?
UK PHIA Probability Yardstick (UK Defence Intelligence)
The Professional Head of Intelligence Assessment publishes a seven-band probability yardstick — Remote chance (under 5%) / Highly unlikely (10-20%) / Unlikely (25-35%) / Realistic possibility (40-50%) / Likely (55-75%) / Highly likely (80-90%) / Almost certain (over 95%). Every probabilistic claim in a MentionFox Donor Vetting Report — wealth-capacity bands, mission-alignment inferences, reputational-risk projections — is expressed using these seven bands, paired with a separate analytical-confidence rating (High / Moderate / Low).
The Twelve Sections of a Donor Vetting Report
| # | Section | Purpose |
|---|---|---|
| 1 | Executive Summary | One opening sentence, one capacity line (PHIA band), one mission-fit line, one risk summary, one headline recommendation. Built last from the eleven other sections so the recommendation reflects the evidence. |
| 2 | Gift Compatibility Assessment | Score out of 100 with four sub-scores: wealth capacity, giving history, mission alignment, reputational risk (inverse — lower score = higher risk). |
| 3 | Wealth Capacity Estimation | Primary wealth source (founder-equity / inherited / executive-comp / fund-mgmt / real-estate / litigation-award / other), estimated net-worth band with PHIA confidence, liquidity signals, capacity for restricted vs unrestricted gifts at multiple ranges. |
| 4 | Philanthropic History & Pattern | Every observable prior gift: amount, recipient, year, restricted vs unrestricted, naming preference. Aggregate giving pattern: total observable, average gift size, sectoral concentration, geographic concentration. |
| 5 | Mission Alignment Signals | Public statements suggesting alignment with the receiving institution's mission. Prior gifts to mission-adjacent organisations, board service, family-member alignment. |
| 6 | Wealth Source Integrity | AML/KYC framing. How the wealth was acquired, ethical concerns surrounding the source, regulatory issues attached to source entity, sanctions / PEP signals. |
| 7 | Reputational Risk Assessment | Tier-A / Tier-B / Tier-C signals calibrated to institution risk tolerance. Recent controversies, ongoing public disputes, social-media-storm risk if named, prior gift retractions or returns by other recipients. |
| 8 | Ongoing Legal Exposure | Civil litigation that names the prospect personally, regulatory investigations, criminal investigations or charges, class actions, recent settlements that might re-surface around naming announcements. |
| 9 | Family Circle Signals | Spouse, children (named where adult and public), family-foundation 990 highlights, multi-generational giving signals. |
| 10 | Board & Advisory Seat History | Nonprofit board seats with engagement-style signals, for-profit boards with donor-relevant signals, exit patterns (term-limit / voluntary / signal-of-displeasure). |
| 11 | Red Flags — Severity-Ranked | HIGH / MEDIUM / LOW aggregate. Sackler / Epstein-style framing only when evidence supports — never invoked lightly. |
| 12 | References & Source Citations | Aggregated audit trail of every URL cited above, deduplicated, grouped by source class (Primary / Authoritative-Secondary / Aggregator / Unverified) per ICD 206 sourcing standards. |
Reputational Risk Tolerance Calibration
The most important methodological choice in a Donor Vetting Report is the explicit refusal to make the gift-acceptance call ourselves. Different nonprofits have different risk tolerances — and that is correct. A research vendor that issues a binary "accept" or "reject" verdict imposes its own ethics on every institution that receives the report, which is inappropriate.
We surface signals at three calibrated tiers so the receiving development office can apply its institution-specific gift-acceptance criteria:
- Tier A — would block a gift at most public universities, hospital foundations, and museum development offices. Examples: SEC fraud findings against the prospect or their primary entity, Sackler-style mass-tort allegations against the wealth source, sanctions designation, criminal conviction in last 10 years, ongoing public boycott of the prospect's primary entity.
- Tier B — would prompt a gift-acceptance committee review at most institutions. Examples: contentious public-policy advocacy on issues adjacent to the institution's mission, controversial-industry employment in last 10 years, prior gift retraction by another peer recipient, divorce settlement with reputational-risk dimension, public conflicts with employees or counterparties.
- Tier C — would be flagged for transparency but not block a gift at most institutions. Examples: routine corporate litigation as a named officer, partisan political donation pattern, opinionated public posts on cultural / social issues that fall outside the institution's mission orbit.
The institution applies its own threshold. Some institutions accept Tier-B signals and decline Tier-A only. Some institutions decline at Tier-B for naming gifts but accept at Tier-B for unrestricted programmatic gifts. Some private foundations accept Tier-A in narrow circumstances when the gift advances the foundation's mission and the foundation can absorb the reputational exposure. The Donor Vetting Report does not make the call; the institution does.
What we will not do: invoke "Sackler" or "Epstein" comparisons unless the evidence in the public record supports the comparison. The reflexive use of those names devalues their warning signal in the cases where it matters.
AML/KYC — Wealth Source Integrity
Anti-money-laundering and know-your-customer compliance is the second methodological body we adopt — applied to the question of how the wealth was acquired. Section 6 (Wealth Source Integrity) screens the prospect's primary wealth source against:
- Sanctions lists. OFAC SDN, EU consolidated, UK HMT, UN sanctions — does the source entity, primary fund, or affiliated business appear on any list?
- Politically-Exposed-Person (PEP) status. Is the prospect a PEP under FATF definitions? Is their immediate family or close business associate? PEP status is not a red flag itself but elevates due-diligence requirements.
- Adverse media on source entity. Negative press in last 5 years on the company / fund / industry that is the prospect's primary wealth source. Fraud allegations, regulatory enforcement, environmental violations, labour disputes, supply-chain controversies.
- Controversial-industry signals. Was the wealth acquired through industries that institutional gift-acceptance committees commonly flag (weapons, opioid-pharma where company faces ongoing litigation, tobacco, gambling, private prisons, surveillance technology, commodity trading with sanctions exposure)? The presence of a signal is information; the institution's gift-acceptance committee applies the threshold.
We do not have access to subscription PEP databases (World-Check, LexisNexis WorldCompliance, Dow Jones, ComplyAdvantage). When PEP screening matters to the gift-acceptance decision, the institution should commission CRA-tier screening separately. The Donor Vetting Report applies the AML/KYC framework to the public record.
Honest Limits — what we do not do
What we DO do
- Synthesis-tier output: 12-section narrative Due Diligence report with cited evidence, calibrated risk tiers, and PHIA-graded probabilities.
- Public methodology: this page. Every framework auditable by peer prospect-researchers, gift-acceptance committee members, and the prospects themselves.
- Asymmetric pricing: 50 credits (about $20) for a full vetting report. Comparable Apra-standard prospect profiles from boutique research firms typically cost $500-$2,500.
- Adopted intelligence-community + prospect-research-profession + AML/KYC frameworks (ICD 203, ICD 206, CASE ethics, Apra standards, AML/KYC, UK PHIA Yardstick) in writing, openly.
What we DO NOT do
- We do not access the prospect's personal financial records, undisclosed transactions, family-trust documents, or private communications.
- We do not access subscription PEP / sanctions databases (World-Check, LexisNexis WorldCompliance).
- We do not access paywalled philanthropic databases (DonorSearch, iWave, Wealth Engine) — though we surface their public sample data where relevant.
- We do not contact the prospect's family, advisors, or peers to gather information. Pretext-gathering and social-engineering are explicitly forbidden by CASE prospect-research ethics; we comply.
- We do not invoke Sackler / Epstein / similar comparisons unless the public-record evidence supports the comparison.
- We do not make the gift-acceptance call. We surface signals at calibrated tiers; the institution decides.
- We do not invent claims to fill thin sections. Where evidence is genuinely absent, the report writes "[insufficient public evidence as of date]" and moves on.
Corrections Policy
Three commitments modeled on the BBC editorial corrections process and Apra prospect-research peer-review practice:
- Identification window. Errors flagged within thirty days of report generation are corrected on the canonical view URL within five business days. Errors flagged after thirty days are evaluated and corrected at our discretion.
- Re-publication, not silent edit. Corrections do not overwrite the prior text silently. The report's view page preserves a redline diff between the original and corrected text, time-stamped, with a one-line explanation. Any reader who saw the original can audit the change.
- Subject right of reply. The prospect named in any Vetting Report may submit a one-paragraph factual rebuttal to corrections@mentionfox.com. Verifiable rebuttals attach to the report alongside the original section. Where the prospect and our research disagree on a public-record claim, both views are surfaced.
Data integrity floor — ALCOA. Every Donor Vetting Report carries an ALCOA Methodology footer: each factual claim is Attributable to a cited source, presented in Legible plain language, marked with the date it was Contemporaneously verified, sourced from the Original primary record where available, and Accurately reflects the underlying evidence with explicit uncertainty flags where evidence is thin. ALCOA is the U.S. Food and Drug Administration's data-integrity principle for regulated industries; we adopt it as the floor for synthesis research because it captures the same disciplines without the regulatory overhang.
References
Primary documents referenced throughout this methodology declaration. All publicly available; we encourage readers to read them in the original.
- ICD 203 — Analytic Standards — Office of the Director of National Intelligence (2015).
- ICD 206 — Sourcing Requirements for Disseminated Analytic Products — Office of the Director of National Intelligence.
- CASE — Council for Advancement and Support of Education — Prospect-research ethics guidelines.
- Apra — Association of Prospect Researchers for Advancement — Methodology standards.
- UK Professional Head of Intelligence Assessment — Probability Yardstick — UK Government / Cabinet Office.
- Bank Secrecy Act — U.S. Treasury / FinCEN.
- FATF Recommendations — Financial Action Task Force.
- EU AMLD5 directive — European Union.
- OFAC SDN list — U.S. Treasury.
- BBC Editorial Guidelines — British Broadcasting Corporation.
- FDA Data Integrity and Compliance With Drug CGMP — ALCOA principles — U.S. Food and Drug Administration.
Methodology v1.0 · Published 2026-05-03 · Verifierce / MentionFox · Vertical 4 of the Due Diligence PlatformFounder methodology → Executive methodology →