Sample Questions - International Activities


Applications for exemption and miscellaneous determination requests are assigned to Exempt Organizations specialists for review. If additional information is necessary to make a determination, a specialist will contact the organization for the information. Here’s a list of questions that might be asked on this topic.

1. Your application indicates that you operate (or will operate) in a foreign country, but did not clearly describe the activity. Please provide the following:

a. Identify the specific countries (and regions within the countries) in which you operate

b. Describe your operations in each country.

2. Please answer the following in regard to Office of Foreign Assets Control (OFAC) compliance:

a. When you conduct activities in foreign countries, will you check the OFAC List of  Specially Designated Nationals and Blocked Persons for names of individuals and entities with whom you are dealing to determine if they are included on the list?

b. What other practices will you engage in to ensure that foreign expenditures or grants are not diverted to support terrorism or other non-charitable activities?

c. Will you comply with all United States statutes, executive orders, and regulations that restrict or prohibit U.S. persons from engaging in transactions and dealings with designated countries, entities, or individuals, or otherwise engaging in activities in violation of economic sanctions administered by OFAC?

d. Will you acquire from OFAC the appropriate license and registration where necessary?

3.  Please answer the following about grants you will make to organizations or individuals located in foreign countries:

a. State the organizations to which you do (or will) distribute funds or goods, and if they have been recognized as tax-exempt by the IRS, state their exempt status.

b. List any distributions (in funds or goods) you made to date, including the recipient, what and how much was disbursed, and how the distribution furthered your exempt purposes.

c. Describe your process for reviewing and approving requests for funds or goods, including the pre-grant inquiries you conduct on potential grantees, and how you determine grant amounts.

d. If you enter into a written grant agreement with grantees, submit representative copies of the grant agreements.

e. If a grant recipient is eligible for repeated grants, explain whether they must reapply and continue to provide information regarding how funds or goods are used.

f. Explain whether you accept donations earmarked for particular organizations or individuals.

g. Specify how you will exercise control and responsibility over the use of any funds or goods granted to foreign organizations or individuals to ensure they are used properly (e.g., requiring grantees to submit periodic reports, or accountings, engaging accountants to audit grantees, sending representatives or agents for field investigations, etc.).

h. Specify to what extent, if any, you share board members or other key personnel with recipient organizations.

Additional information

See the complete list of Applying for Exemption/Miscellaneous Determination Sample Questions by topic.