SP Sanctions Enforcement FY 25 NOFO DFOP0017256 - 30 May 2025.docx
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- Enforcing Sanctions on China and Russia
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- DFOP0017256
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This document is a Notice of Funding Opportunity (NOFO) from the U.S. Department of State's International Security and Nonproliferation Office of Cooperative Threat Reduction, focusing on enforcing sanctions against China and Russia. The opportunity seeks to award approximately $19,500,000 through 10 grants ranging from $250,000 to $5,000,000, with a performance period of 12-24 months and a projected start date of January 1, 2026. Eligible applicants include U.S. for-profit and non-profit organizations, educational institutions, foreign non-profits, and public international organizations.
The grant program aims to help partners identify and disrupt sanctions evasion strategies by China and Russia across four primary sectors: financial institutions, private sector technology and manufacturing, trade and logistics, and public sector enforcement entities. Target countries span multiple regions, including parts of Asia, Europe, and the Middle East. Proposals must address objectives such as organizing technical trainings, developing open-source data tools, conducting investigative analyses, and creating resources to strengthen sanctions compliance and enforcement. The application deadline is July 30, 2025, with the funding instrument being grants or cooperative agreements under the Nonproliferation, Antiterrorism, Demining and Related Programs (NADR) account.
NOFO Guidance
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| CTR NOFO Q&A - posted 8 July.docx | DOCX document | |
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| SP Sanctions Enforcement FY 25 NOFO DFOP0017256 - 6 June 2025.docx | DOCX document |
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Notice of Funding Opportunity (NOFO)
Enforcing Sanctions on China and Russia INTERNATIONAL SECURITY AND NONPROLIFERATION OFFICE OF COOPERATIVE THREAT REDUCTION, DEPARTMENT OF STATE Opportunity number: DFOP0017256 Application deadline: 30 July 2025, 11:59 P.M. EDT
Contents
| A. | Basic Information | 3 |
| B. | Eligibility | 4 |
| C. | Program Description | 5 |
| D. | Application Contents and Format | 5 |
| E. | Submission Requirements and Deadlines | 7 |
| F. | Application Review Information | 10 |
| G. | Award Notices | 12 |
| H. | Post-Award Requirements and Administration | 12 |
| I. | Other Information | 14 |
U.S Department of State
INTERNATIONAL SECURITY AND NONPROLIFERATION OFFICE OF
COOPERATIVE THREAT REDUCTION
Notice of Funding Opportunity
A. Basic Information
1. Overview
| Funding Opportunity Title |
| Implementing China and Russia Sanctions |
| Funding Opportunity Number |
| DFOP0017256 |
| Announcement Type |
| Initial Announcement |
| Deadline for Applications |
| 30 July 2025, 11:59 P.M. EDT |
| Assistance Listing Number |
| 19.033 |
| Length of performance period |
| 12-24 months |
| Number of awards anticipated |
| 10 awards (dependent on amounts) |
| Award amounts |
| Awards may range from a minimum of $250,000 to a maximum of $5,000,000(approximately) |
| Total available funding |
| $19,500,000 pending availability of funds |
| Type of Funding |
| FY 25/26 Nonproliferation, Antiterrorism, Demining and Related Programs (NADR) and other accounts and focuses on mitigating weapons of mass destruction (WMD) and WMD-related delivery systems proliferation and security threats from proliferator states and non-state actors. |
| Anticipated project start date |
| 1 January 2026 |
Funding Instrument Type: Grant, cooperative agreement, Inter-Agency Agreements (IAA), Cooperative agreements include substantial involvement of the bureau or embassy in program implementation of the project.
Project Performance Period: Proposed projects should be completed in 15 months or less.
This notice is subject to availability of funding.
2. Executive Summary
Priority Region: East Asia Pacific (EAP) Executive Summary China and Russia systematically exploit global supply chains and the U.S. financial system to acquire proliferation-sensitive goods and technologies and support onward proliferation through illicit trade networks. These actions are in violation of U.S. and international laws and regulations and undermine American security and prosperity and the security of our partners and allies.
ISN/CTR conducts global national security programming that counters illicit procurement, investment schemes, and financing networks that China and Russia use to exploit international trade and finance. U.S. and partner country sanctions and economic deterrents target the nodes and sectors that enable China’s & Russia’s military modernization and sanctions evasion efforts; however, these tools are only as strong as their implementation and enforcement around the globe.
ISN/CTR provides partners with enhanced capabilities to identify and disrupt complex sanctions evasion strategies and understand the risks of noncompliance (e.g. potential secondary sanctions). ISN/CTR accomplishes this through technical engagements that provide resources to assist partners to identify and avoid transactions with designated entities, and their associated networks. Engagements are tailored to discrete audiences within the public and private sector and address region or jurisdiction-specific issues.
B. Eligibility
1. Eligible Applicants The following organizations are eligible to apply: U.S. for-profit organizations or businesses; U.S.-based non-profit/non-governmental organizations with or without 501(c) (3) status of the U.S. tax code; U.S.-based private, public, or state institutions of higher education; foreign-based non-profit organizations/non-government organizations (NGO); Federally Funded Research and Development Centers (FFRDCs); Public International Organizations (PIO) ; Foreign Public Entities (FPE); and foreign-based institutions of higher education.
2. Cost Sharing or Matching Providing cost sharing, matching, or cost participation is not an eligibility factor or requirement for this NOFO and providing cost share will not result in a more favorable competitive ranking. Per 2 CFR §200.306, items that are proposed for cost share must be allowable per 2 CFR §200, Subpart E—Costs Principles.
Voluntary cost-share: Should the applicant choose to contribute voluntary cost-share but does not meet the minimum amount of the voluntary cost-sharing stipulated in the applicant’s budget, DOS’ contribution may be reduced in proportion to the applicant’s contribution.
3. Other Eligibility Requirements All organizations must have a Unique Entity Identifier (UEI) issued via SAM.gov as well as a valid registration in SAM.gov. Please see Section D.3 for more information.
Applicants can submit one application in response to the NOFO. If more than one application is submitted by an organization, only the final application received, and time stamped by grants.gov will be reviewed for eligibility. Each application can include multiple projects that will be evaluated independently.
C. Program Description
1. Goals and Objectives To help partners identify these increasingly complex sanctions evasion strategies and take action to stop them, ISN/CTR provides expert resources and technical engagements to identify and avoid transactions with designated Chinese and Russian entities and their associated networks. As the evasion landscape has evolved to become more complex, engagements have expanded from traditional compliance, investigatory, and enforcement bodies to include strategy & operations, sales departments, business owners, and investors, etc.
ISN/CTR is specifically interested in tailored programs and resources that are designed to empower public and private sector entities to strengthen sanctions compliance. Through detailed instruction and open-source data research tools, ISN/CTR will reduce proliferation risks and disrupt sanctions evasion entities and networks in the following areas:
· Private Sector:
· Bank and Non-bank Financial Institutions
· Designated Non-Financial Business and Professions
· Dual-use Manufacturing and Technology Startups & Businesses
· Trade & Logistics Sectors
· Public Sector, including enforcement, investigatory, and regulatory bodies
Project Goal Engage foreign audiences on identifying and taking action against complex sanctions evasion entities and networks. Projects should be cost effective and create self-sustaining improvements in sanctions compliance and enforcement.
Objectives
i. Targeted Financial Sector Sanctions Engagements: Sanctions evasion tactics used by China and Russia rely upon continued access to the global financial market to facilitate acquisition of proliferation-sensitive goods and technologies and support onward proliferation through illicit trade networks. These programs will engage financial private sector entities to provide technical training and tools in order to improve compliance with U.S. and other international sanctions regimes imposed on U.S. adversaries:
Objective: Plan and organize technical trainings and follow-on private consultations on sanctions regimes that will bring together 20-50 stakeholders per event. The events should aim to reach small and medium sized firms, with weaker compliance systems, and should focus on improving due diligence, conducting investigations, demonstrating regulator data-sharing, highlighting risks, etc.
Objective: Bring timely, relevant, and applicable case studies, using open-source information to the private sector that show active sanctions evasion exposure within the jurisdiction. Organizers should analyze audiences prior to engagements to tailor materials and case-studies to reach action-oriented results. Organizers can provide access to tools for participants following the engagement.
Objective: Use commercially available and open-source data to develop and disseminate reports that help partners identify beneficial ownership structures, subsidiaries, lenders, financiers, and other links to sanctioned or prohibited entities.
Objective: Deliver trainings that build on, and expand beyond, what ISN/CTR has offered to-date by tailoring to new regulatory developments, compliance guidance, countries of emerging risk, and links to sanctioned or prohibited entities.
Objective: Plan and organize trainings for smaller groups that focus on improving private sector coordination with the public sector, including the relevant authorities and regulators.
Objective: Plan and organize partnerships with key stakeholders which will facilitate ongoing training and assistance over the course of the project period of performance. Implement programs to provide regular access to technical experts and tools for stakeholders to support their ongoing development of strong sanctions compliance frameworks, investigations, and risk-mitigation processes.
Objective: Provide access to open-source tools and experts who enable analysis and investigation of large datasets that show where and how global trade and financial networks are manipulated by China and Russia to evade nonproliferation sanctions. Further, to provide data and analyses on types of goods, trade volumes, and entities involved in illicit procurement networks. Turn these analyses into actionable reports for non-technical internal and external audiences that highlight violations of sanctions and/or risks indicating potential violations.
Objective: Provide access to open-source tools and experts who enable analysis and investigation of entities, individuals, vessels, and aircraft likely associated with evasion of nonproliferation sanctions by China and Russia. Turn these analyses into actionable reports for non-technical internal and external audiences that highlight violations of sanctions, networks of enablers, and risk typologies present in evasion tactics.
Countries: Albania, Armenia, Azerbaijan, Bahamas, Belize, Bolivia, Bosnia and Herzegovina, Bulgaria, Cayman Islands, Croatia, Cyprus, Czechia, Estonia, Finland, France, Georgia, Greece, India, Indonesia, Ireland, Japan, Kazakhstan, Kyrgyzstan, Latvia, Lithuania, Luxembourg, Malaysia, Maldives, Malta, Marshall Islands, Moldova, Montenegro, Netherlands, North Macedonia, Panama, Philippines, Poland, Republic of Korea, Romania, Singapore, Slovakia, Slovenia, Spain, St Kitts and Nevis, Switzerland, Taiwan, Thailand, Tunisia, Türkiye, UAE, Vietnam
ii. Counter Private Sector Sanctions Evasion: Chinese and Russian actors work to exploit dual-use advanced technology and manufacturing sectors to support their own military capabilities and advance their weapons programs. ISN/CTR’s capacity-building work looks to engage key private sector stakeholders within the dual-use advanced technology and manufacturing sectors to counter this activity. Key stakeholders could include startups & businesses developing advanced materials, software, machine tools, and microelectronics.
Objective: Support targeted, private consultations with advanced technology and manufacturing firms to help de-risk supply chains away from sanctioned or prohibited networks.
Objective: Plan and organize capacity building and technical events that will bring together 20-50 stakeholders per event. The events should engage industry partners (suppliers, shippers, intermediaries, other supply-chain stakeholders) to demonstrate areas of exposure to prohibited Chinese and other malign entities and the reputational and sanctions risks associated with transacting with designated entities in these assets/sectors.
Objective: Plan and organize small, targeted events that engage regulatory bodies, trade associations, and other appropriate sector representatives on the need for strong compliance, control tools, and due diligence to ensure maximum transparency when addressing Chinese and other malign entities sanctions evasions tactics in the sector.
Objective: Provide access to open-source tools and experts who enable analysis and investigation of large datasets that show where and how global trade and financial networks are manipulated by China and Russia to evade nonproliferation sanctions. Further, to provide data and analyses on types of goods, trade volumes, and entities involved in illicit procurement networks. Turn these analyses into actionable reports for non-technical internal and external audiences that highlight violations of sanctions and/or risks indicating potential violations.
Objective: Provide access to open-source tools and experts who enable analysis and investigation of entities, individuals, vessels, and aircraft likely associated with evasion of nonproliferation sanctions by China and Russia. Turn these analyses into actionable reports for non-technical internal and external audiences that highlight violations of sanctions, networks of enablers, and risk typologies present in evasion tactics.
Countries: Cyprus, Czechia, Estonia, Finland, France, Georgia, India, Indonesia, Italy, Japan, Latvia, Lithuania, Luxembourg, Malaysia, Maldives, Malta, Netherlands, Philippines, Poland, Republic of Korea, Singapore, Slovakia, Slovenia, Switzerland, Taiwan, Thailand, Türkiye, UAE, Vietnam.
iii. Counter Trade & Logistics Sanctions Evasion Chinese and Russian actors continue to leverage vessels, aircraft, and ground transportation services to move technology and goods that help them circumvent sanctions. While many jurisdictions have taken steps to de-risk, sanctions evaders continuously seek out new jurisdictions, routes, registries, shippers, and distributors with weak compliance standards to enable their illicit activity. ISN/CTR’s national security programming works to engage key public and private sector stakeholders to counter this illicit trade and logistics sanctions circumvention in the maritime, aviation, and ground transportation sectors.
Objective: Plan and organize capacity building and technical events that will bring together 20-50 stakeholders per event. The events should provide both public and private maritime, aviation, and ground transportation stakeholders with timely and in-depth investigative support to counter Chinese and Russian entities sanctions evasion activity through international trade and logistics channels.
Objective: Plan and organize capacity building and technical events that target the following stakeholders: partner governments, chartering services/owners, flag registries, banks, insurance companies, port operators and other maritime stakeholders to shed light on findings/behaviors of suspicious vessels and associated maritime entities.
Objective: Events should focus on improving due diligence and supporting investigations that address challenges that can include, ship-to-ship transfers; obfuscation of transshipment information; vessel location manipulation; forged bills of lading/cargo manifests; turning away, addressing, or seizing a designated vessel; etc.
Objective: Plan and organize capacity building and technical events related to the following stakeholders: Provide public and private aviation and airfreight partners, ground transportation & logistics providers, and freight forwards with timely and in-depth investigative support to counter Chinese and other malign sanctions evasion.
Objective: Engagements should enhance understanding associated with transshipment of goods and services and associated risks through air and ground transport services and logistics. It should also shed light on safety risks posed by potentially unairworthy aircraft and identify illicit supply chain networks for aviation spare parts in violation of sanctions and control regulations.
Objective: Provide access to open-source tools and experts who enable analysis and investigation of large datasets that show where and how global trade and financial networks are manipulated by China and Russia to evade nonproliferation sanctions. Further, to provide data and analyses on types of goods, trade volumes, and entities involved in illicit procurement networks. Turn these analyses into actionable reports for non-technical internal and external audiences that highlight violations of sanctions and/or risks indicating potential violations.
Objective: Provide access to open-source tools and experts who enable analysis and investigation of entities, individuals, vessels, and aircraft likely associated with evasion of nonproliferation sanctions by China and Russia. Turn these analyses into actionable reports for non-technical internal and external audiences that highlight violations of sanctions, networks of enablers, and risk typologies present in evasion tactics.
Countries: Armenia, Azerbaijan, Bahamas, Belize, Cayman Islands, Comoros, Croatia, Cyprus, Democratic Republic of Congo, Eswatini, Fiji, Gabon, Greece, Guyana, India, India, Indonesia, Ireland, Kazakhstan, Kiribati, Kyrgyzstan, Malaysia, Maldives, Malta, Marshall Islands, Mauritius, Netherlands, Panama, Philippines, Sao Tome and Principe, Serbia, Seychelles, Spain, Taiwan, Thailand, Tunisia, Türkiye, UAE, Vietnam.
iv. Targeted Public Sector Sanctions Outreach: Russian and Chinese actors’ sanctions evasion schemes seek to heavily infiltrate a number of sectors (financial, industry, maritime, aviation, logistics, etc.) that various public sector authorities and regulators are responsible for monitoring and overseeing. ISN/CTR collaborates with these organizations to share knowledge about sanctions regulations, build trust between the public and private sector, and ultimately strengthen compliance and enforcement practices. These programs will engage public sector entities through the following objectives:
Objective: Plan and organize technical consultations and private meetings for private sector policy and enforcement entities. These engagements will be more targeted than a large workshop. These public sector engagements should be implemented as technical engagements/exchanges where organizers engage organizations or agencies individually, instead of as part of a larger training. These technical consults should aim to reach investigatory bodies (to include financial intelligence units, law enforcement, and regulators) to train them to identify sanctions evasion networks linked to Chinese and Russian actors. In some cases, there is benefit to including public sector audiences together with private sector stakeholders to promote strong public/private sector partnerships, improve understanding of regulations, and foster robust communication on topics of sanctions compliance and enforcement.
Objective: Plan and organize partnerships with key public sector stakeholders which will facilitate ongoing training and assistance over the course of the project period of performance. Implement programs to provide regular access to technical experts and tools for stakeholders to support their ongoing development of strong sanctions compliance frameworks, investigations, and risk-mitigation processes.
Objective: Provide access to open-source tools and experts who enable analysis and investigation of large datasets that show where and how global trade and financial networks are manipulated by China and Russia to evade nonproliferation sanctions. Further, to provide data and analyses on types of goods, trade volumes, and entities involved in illicit procurement networks. Turn these analyses into actionable reports for non-technical internal and external audiences that highlight violations of sanctions and/or risks indicating potential violations.
Objective: Provide access to open-source tools and experts who enable analysis and investigation of entities, individuals, vessels, and aircraft likely associated with evasion of nonproliferation sanctions by China and Russia. Turn these analyses into actionable reports for non-technical internal and external audiences that highlight violations of sanctions, networks of enablers, and risk typologies present in evasion tactics.
Objective: Provide public sector enforcement entities in partner countries with commercially available tools related to risks and links to sanctioned or prohibited entities.
Countries: Armenia, Azerbaijan, Bahamas, Belize, Bosnia and Herzegovina, Bulgaria, Cayman Islands, Cyprus, Czechia, Estonia, Finland, Georgia, Ireland, Japan, Latvia, Lithuania, Luxembourg, Malaysia, Maldives, Malta, Moldova, Montenegro, Netherlands, North Macedonia, Panama, Philippines, Poland, Republic of Korea, Romania, Singapore, Spain, Switzerland, Taiwan, Thailand, Tunisia, Türkiye, UAE.
2. Substantial Involvement ISN/CTR will be involved in the project development and planning. ISN/CTR staff will work closely with the implementer to select participants, grant awards, and review event agendas, curriculum, and all other materials to ensure that they align with the proficiency level, needs and interests of each ISN/CTR partner country audience. ISN/CTR will approve all foreign participant, advise on training logistical implementation and will consult on all aspects of event logistical planning and all participants including process and lead-time required for obtaining U.S. visas.
D. Application Contents and Format Please follow all instructions below carefully. Proposals that do not meet the requirements of this announcement or fail to comply with the stated requirements will be ineligible.
ISN/CTR is looking for one proposal package per application. Each package can include multiple standalone projects that can evaluated independently. Each proposal packet will include one of the following documents that incorporate information on all proposed projects: SF-424, SF-424A, SF-424B (Optional), SF-LLL (if Applicable), Summary Page, Key Personnel, Monitoring and Evaluation Narrative, and a Monitoring and Evaluation Plan/Tracker. To ensure that all applications receive a balanced evaluation, the review panel will review from the first page of each section up to the page limit and no further. Each proposed project should have a unique set of the following documents: Project Narrative, Detailed Line-Item Budget Document, and Budget Narrative Document.
Content of Application Please ensure:
· The proposal clearly addresses the goals and objectives of this funding opportunity
· All documents are in English
· All budgets are in U.S. dollars (no cents)
· All pages are numbered
· All documents are formatted to fit 8 ½ x 11 paper, and
· All Microsoft Word documents are single-spaced, 12 point Calibri font, with a minimum of 1-inch margins. Font sizes in charts and tables, including the budget, can be reformatted to fit within 1 page width.
· All application materials must be submitted through www.Grants.gov unless you are a U.S. government entity applying for Inter-Agency Agreement (IAA) funding. If you are applying for an IAA please submit proposals to ctrspecialprojectsproposals@state.gov and ISN-CTR-BUDGET@state.gov.
The following documents are required:
1. Mandatory application forms
· SF-424 (Application for Federal Assistance – organizations)
· SF-424A (Budget Information for Non-Construction programs)
2. Optional Application Forms
· SF-424B forms (strongly encouraged for for-profit entities and other organizations (FPEs/PIOs))
· SF-LLL (Disclosure of Lobbying Activities)
3. Summary Page Include a table with the organization name, project title, target country/countries, name and contact information for the application’s main point of contact, and brief section that clearly outlines the (1) the problem statement addressed by the project (2) research-based evidence justifying the applicant’s approach, and (3) quantifiable project outcomes. (Template not provided, not to exceed one (1) page, preferably as a Word document)
4. Key Personnel Identify staff within your organization or outside of your organization (subgrantee, consultants, contractors), carrying out administrative and/or technical responsibilities, who are integral to the success of each project. Provides names, titles, roles and experience/qualifications, time they will support each project of key personnel involved in each project. Given the limited space, inserting CVs are not recommended but may be submitted in as an attachment. Generally limited to 3-5 individuals. (Template not provided, not to exceed two (2) pages, preferably as a Word document).
5. Program Monitoring and Evaluation Narrative and Plan/Tracker This is a two (2) component submission requirement. (Template not provided)
(1) Monitoring and Evaluation Narrative: (3 pages maximum) Preferably a one-page Word document, the narrative outlines how a project’s M&E system will be carried out and by whom. It details how you will track your project’s performance toward its objectives over time and provides a clear description of the approach and data collection strategies and tools to be employed (e.g., pre- and post-test surveys, interviews, focus groups). The description should include how the applicant will track and document whether activities occurred (outputs) and the results or changes caused by these activities (outcomes). If the project includes work with local partners or sub-partners, explain how M&E efforts will be coordinated amongst these organizations. Explain if an external evaluation will be included. Evaluations, internal or external, should be systematic studies that use research methods to address specific questions about project performance. They should provide a valuable supplement to ongoing monitoring activities. Evaluation activities generally include baseline assessments, mid-term and final evaluations.
(2) Monitoring and Evaluation Plan:
The monitoring and evaluation (M&E) plan should draw on the objectives, activities and expected changes outlined in the proposal, and link those areas to indicators. The M&E plan is generally structured as an Excel table with output- and outcome-based indicators. It explains how data will be collected (data collection methods) to measure the effect of programming against declared objectives. It outlines baselines (where your project is starting) and quarterly targets (what you would like to achieve) for each indicator. Please see “Sample Monitoring Indicator Plan” included as an attachment to the NOFO.
Note: If recommended for funding, the panel and/or bureau may negotiate the inclusion of additional Department of State Foreign Assistance indicators. These indicators assist the bureau in tying projects to larger bureau program objectives for Department’s Managing for Results framework. More information on this policy framework and access to the foreign assistance master indicator list is on the Foreign Assistance Resource Library. After award issuance, the M&E plan will accompany performance reports to document progress on indicators.
6. Project Narrative (3 pages maximum per project) The proposal should contain sufficient information that anyone not familiar with it would understand exactly what the applicant wants to do. You may use your own proposal format, but it must include all the items below. (Please use the provide template)
· CTR Unique Identifier: Please assign each project a unique identifier based on the following convention: Implementer_Country_Fiscal Year_001 (IMPL_EFF_YR_001).
· Project Summary: Short narrative that outlines the proposed project, including project objectives and anticipated impact.
· Introduction to the Organization or Individual applying: A description of past and present operations, showing ability to carry out the program, including information on all previous grants from the State Department and/or U.S. government agencies.
· Project Title: Please provide a one-sentence project title that succinctly describes the project and outcome.
· Problem Statement: Clear, concise and well-supported statement of the problem to be addressed and why the proposed program is needed
· Project Goals and Objectives: The “goals” describe what the program is intended to achieve. The “objectives” refer to the intermediate accomplishments on the way to the goals. These should be achievable and measurable.
· Project Activities and Deliverables: Describe the program activities and how they will help achieve the objectives.
· Project Methods and Design: A description of how the program is expected to work to solve the stated problem and achieve the goal. Include a logic model as appropriate.
· Outcomes: The results or effects of the objective(s). What are the detailed, measurable statements that outline the end results?
· Risk Analysis: Risks are unavoidable – all projects inherently contain both internal and external risks.
· Proposed Project Schedule and Timeline: The proposed timeline for the program activities. Include the dates, times, and locations of planned activities and events.
· Project Partners: List the names and type of involvement of key partner organizations and sub-awardees.
· Future Funding or Sustainability Applicant’s plan for continuing the program beyond the grant period, or the availability of other resources, if applicable.
· Country of Impact: If a project will provide assistance to more than one country, please specify the estimated percent of funds that will be provided to each country.
· Nonproliferation Objective and the Project’s Role in Meeting this Objective: Please provide a specific explanation of how your proposed activities will meet the nonproliferation objectives outlined in the NOFO.
· Participant Review Acknowledgment: If the proposal includes virtual or in person engagements your organization will need to submit participant information to CTR using the CTR participant review spreadsheet.
· Project Budget: Please include the top line total for the projects and complete the separate budget attachments.
· Project Point of Contact (POC)
7. Budget Justification Documents After filling out the SF-424A Budget (above), use submit two separate files for each project proposed to describe each of the budget expenses in detail. Please submit See section I. Other Information: Guidelines for Budget Submissions below for further information. (Please use the provide template)
(1) Detailed Line-Item Budget Document:
Entities and organizations not recognized as FFRDCs, FPEs, or PIOs are required to submit detailed budget information according to the OMB cost categories (see SF-424A as an example). Budget expenses should be submitted preferably as one Excel workbook and include three (3) columns describing the request to ISN/CTR, any required or voluntary cost sharing, and the total budget. If submitting multiple projects each project can have its own page in the workbook. Costs must be in whole U.S. dollars. The attached Budget Guidance Template is the preferred format for submission. Detailed line-item budgets for sub-grantees should be included as additional tabs within the Excel workbook (if available at the time of submission).
(2) Budget Narrative Document: (3 Pages maximum) Entities and organizations not recognized as FFRDCs, FPEs, or PIOs are required to submit narrative information, preferably as a Word document, that explain the methodology considerations for each specific line identified in the Excel document. The budget narrative should support the activities described in the proposal and provide additional information that might not be readily apparent in the detailed line-item budget. Do not simply repeat what is represented numerically in the budget, i.e. salaries are for salaries or travel is for travel. If the detailed budget includes sub-awards, please include a separate budget narrative for each sub-award budget. Provide details on the purpose of costs, reasonability of costs, cost price analysis, allocation methodology, explain any yearly variances in unit prices, and tie expenses to program activities and/or objectives where appropriate. Information should describe prices used when costs have been averaged for the purposes of the calculation; when or if there is a reduction in a typical cost due to leveraging other resources; when costs are inflated due to specific considerations; or when untypical costs are included due to special circumstances. Provide information on considerations such as translations, multi-media approaches as also described in the proposal narrative, procurement by local vendors or the need to import due to unavailability, specific needs of different audiences, costs related to country limitations, etc.
Budget Documents for Foreign Public Entities/Public International Organizations: Entities and organizations recognized as FFRDCs, FPEs, or PIOs are not required to submit detailed budget information according to the OMB cost categories. (1) A detailed budget, preferably as an excel document broken down by activity may be provided instead. Costs must be in U.S. dollars. (2) A budget narrative, preferably as an Excel workbook, an activity based detailed budget with information identifying lines associated with labor (inclusive of contractual or consultancy staff), participant support costs, travel, and other activity related expenses as appropriate for each activity identified. While 2 CFR 200, Subpart E—Costs Principles does not apply to FFRDCs, FPEs, or PIOs, it should be used as a guide to assist in determining reasonableness. Budget narrative information, preferably as a Word document, should explain the methodology considerations for each activity and other cost considerations or special circumstances that are helpful in determining reasonableness.
8. Attachments that will be included in evaluation
· 1-page Curriculum Vitae (CV) or resume of key personnel who are proposed for the program.
· If your organization has a Negotiated Indirect Cost Rate Agreement (NICRA) and includes NICRA charges in the budget, include your latest NICRA as a PDF file.
· Past Performance statement please provide a list of recent USG funded awards (max 10) that have been active in the last twenty-four (24) months with references and award numbers.
· Official permission letters, if required for program activities.
E. Submission Requirements and Deadlines
1. Address to Request Application Package Application forms required above are available at grants.gov and MyGrants.
2. Department of State Contacts If you have any questions about the grant application process, please contact: ISN-CTR-BUDGET@state.gov and ctrspecialprojectsproposals@state.gov.
ISN/CTR will not conduct individual meetings to discuss the specifics of a proposal or provide additional information on the needs of the NOFO before they close. ISN/CTR will collect all questions about this NOFO submitted to the distros above and post the questions and answers as an attachment to the NOFO in Grants.gov every Friday until 25 July 2025.
3. Unique entity identifier and System for Award Management (SAM.gov) Required Registrations All organizations, whether based in the United States or in another country, must have a Unique Entity Identifier (UEI) and an active registration in SAM.gov. A UEI is one of the data elements mandated by Public Law 109-282, the Federal Funding Accountability and Transparency Act (FFATA), for all Federal awards. An applicant must maintain an active registration while it has a proposal under review by the Department and must continue to keep the registration active for the entire duration of the period of performance of any Federal award that results from this NOFO.
The 2 CFR 200 requires subrecipients to obtain a UEI. Please note the UEI for subrecipients is not required at the time of application but will be required before an award is processed and/or directed to a subrecipient.
Note: The process of obtaining or renewing a SAM.gov registration may take anywhere from 4-8 weeks. Please begin your registration as early as possible.
· Organizations based in the United States or that pay employees within the United States will need an Employer Identification Number (EIN) from the Internal Revenue Service (IRS) and a UEI prior to registering in SAM.gov.
· Organizations based outside of the United States and that do not pay employees within the United States do not need an EIN from the IRS but do need a UEI prior to registering in SAM.gov.
· Organizations based outside of the United States that do not intend to apply for U.S. Department of Defense (DoD) awards are no longer required to have a NATO Commercial and Government Entity (NCAGE) code to apply for non-DoD foreign assistance funding opportunities. If an applicant organization is mid-registration and wishes to remove an NCAGE code from their SAM.gov registration, the applicant should submit a help desk ticket (“incident”) with the Federal Service Desk (FSD) online at www.fsd.gov using the following language: “I do not intend to seek financial assistance from the Department of Defense. I do not wish to obtain an NCAGE code. I understand that I will need to submit my registration after this incident is resolved in order to have my registration activated.”
Organizations based outside of the United States and that DO NOT plan to do business with the DoD should follow the below instructions:
Step 1: Proceed to SAM.gov to obtain a UEI and complete the SAM.gov registration process. SAM.gov registration must be renewed annually.
Organizations based outside of the United States and that DO plan to do business with the DoD in addition to Department of State should follow the below instructions:
Step 1: Apply for an NCAGE code by following the instructions on the NSPA NATO website linked below:
NCAGE Homepage:
https://eportal.nspa.nato.int/AC135Public/sc/CageList.aspx NCAGE Code Request Tool (NCRT):
NCAGE Code Request Tool (nato.int)
Exemptions An exemption from the UEI and sam.gov registration requirements may be permitted on a case-by-case basis. See 2 CFR 25.110 for a full list of exemptions.
Organizations requesting exemption from UEI or SAM.gov requirements must email the point of contact listed in the NOFO at least two weeks prior to the deadline in the NOFO providing a justification of their request. Approval for a SAM.gov exemption must come from the warranted Grants Officer before the application can be deemed eligible for review.
4. Submission Dates and Times Applications are due no later than 30 July 2025, 11:59 P.M. EDT
5. Funding Restrictions
i. Funding Restrictions for the United Nations Relief and Works Agency (UNRWA)
None of the funds awarded resulting from this Notice of Funding Opportunity may be made available for subawards, direct financial support, or otherwise used to provide any payment or transfer to United Nations Relief and Works Agency (UNRWA).
ii. Prohibition on Funding Activities that Encourage Mass-Migration Caravans towards the United States Southwest Border
None of the funds awarded under this grant may be made available to encourage, mobilize, publicize, or manage mass-migration caravans towards the United States southwest border. Funds may not be made available for legal counseling on the United States asylum process; and/or for referrals to legal representation in the United States.
Funds may only be used for cash cards for use in the country in which they are provided or to facilitate assisted voluntary returns and other purposes that do not encourage, mobilize, publicize, or manage mass migration caravans towards the United States southwest border. The provision of humanitarian assistance is permitted.
iii. Certification Regarding Compliance with applicable Federal anti-discrimination laws
None of the funds awarded under this agreement may be used for any initiatives or programs, or any activities that do not comply with Executive Order 14173 titled Ending Illegal Discrimination and Restoring Merit-Based Opportunity.
By signing the SF-424 or SF-424I Application for Federal Assistance, the Applicant certifies the following:
1) Its compliance in all respects with all applicable Federal anti-discrimination laws is material to the government’s payment decisions for purposes of section 3729(b)(4) of title 31, United States Code and;
2) It does not operate any programs promoting Diversity, Equity, and Inclusion that violate any applicable Federal anti-discrimination laws.
iv. Applicants are advised that IHEs must certify the following at the time of award, and that this certification requirement must be included in any subaward agreements to IHEs:
· Its compliance in all respects with section 1011f of title 20, United States Code, and any other applicable foreign funding disclosure requirements is material for purposes of section 3729 of title 31, United States Code, and for receipt of appropriate Federal grant funds.
ISN/CTR will not consider applications that reflect any type of support for any member, affiliate, or representative of a designated terrorist organization. Please refer to the link for Foreign Terrorist Organizations: https://www.state.gov/foreign-terrorist-organizations/. Consistent with Department guidance on State Funding and the Risks of Terrorist Financing for all State Department funded programs and requirements, Department bureaus must assess the likelihood that the funds or Department funded activities, goods, services, training, expert advice or assistance, or other benefits to be provided, could inadvertently or incidentally benefit terrorist organizations or their members or supporters, and must put in place appropriate risk mitigation measures to mitigate such risk. In accordance with 14 FAM 247, and consistent with 2 FAM 050, Counterterrorism (CT) name-check vetting may be performed in countries and programs designated by the Department.
The Leahy Law prohibits Department foreign assistance funds from supporting foreign security force units if the Secretary of State has credible information that the unit has committed a gross violation of human rights. Per 22 USC §2378d(a) (2017), “No assistance shall be furnished under this chapter or the Arms Export Control Act [22 U.S.C. 2751 et seq.] to any unit of the security forces of a foreign country if the Secretary of State has credible information that such unit has committed a gross violation of human rights.” Restrictions may apply to any proposed assistance to police or other law enforcement. Among these, pursuant to section 620M of the Foreign Assistance Act of 1961, as amended (FAA), no assistance provided through this funding opportunity may be furnished to any unit of the security forces of a foreign country when there is credible information that such unit has committed a gross violation of human rights. In accordance with the requirements of section 620M of the FAA, also known as the Leahy law, project beneficiaries or participants from a foreign government’s security forces may need to be vetted by the Department before the provision of any assistance. If a proposed grant or cooperative agreement will provide assistance to foreign security forces or personnel, compliance with the Leahy Law is required.
U.S. foreign assistance for Burma or Burmese beneficiaries is subject to restrictions. This includes restrictions pursuant to section 7043(a)(3) of the Department of State, Foreign Operations, and Related Programs Appropriations Act, 2020 (Div. G, P.L. 116-94)(SFOAA), on funds appropriated under Title III of the Act for Assistance for Burma. Section 7043(a)(3) provides that such funds “may not be made available to any organization or entity controlled by the armed forces of Burma, or to any individual or organization that advocates violence against ethnic or religious groups or individuals in Burma, as determined by the Secretary of State.” In addition, funds cannot be made available to any individual or organization that has committed serious human rights abuse.
The Department has a legal requirement, established by section 861 of the National Defense Authorization Act for Fiscal Year 2008 and implemented through subsequent regulations, to report and account for all contractors working under grants or cooperative agreements in contingency operations outside the United States that involve combat operations. The common database to collect this information, called the Synchronized Pre-deployment Operational Tracker (SPOT), is managed by the Department of Defense. A Department SPOT Program Manager, based in A/OPE/AQM/BOD (AQMops@state.gov) generally enters information provided by the recipients directly into the SPOT system. Currently the Department applies this requirement to awards operating in Iraq or Afghanistan.
The following activities and costs are not covered under this announcement (this list is NOT exhaustive):
· Projects intended primarily for the growth or institutional development of the applicant organization;
· Projects seeking funds for personal use;
· Administration of a project that will make a profit;
· Expenses incurred before or after the specified dates of award period of performance (unless prior written approval is received);
· Projects designed to advocate policy views or positions of foreign governments or views of a particular political faction;
· Alcoholic beverages;
· Costs of entertainment, including amusement, diversion, and social activities, and any associated costs, are unallowable, except where specific costs that might otherwise be considered entertainment have a programmatic purpose and are authorized either in the approved budget for the federal award or with prior written approval of the Grants Officer.
Representation by Organization Regarding a Delinquent Tax Liability or a Felony Criminal Conviction: In accordance with section 7073 of Division K of the Consolidated Appropriations Act, 2014 (Public Law 113-76) none of the funds made available by that Act may be used to enter into an assistance award with any organization that –
· (1) Was “convicted of a felony criminal violation under any Federal law within the preceding 24 months, where the awarding agency has direct knowledge of the conviction, unless the agency has considered, in accordance with its procedures, that this further action is not necessary to protect the interests of the Government”; or
· (2) Has any “unpaid Federal tax liability that has been assessed for which all judicial and administrative remedies have been exhausted or have lapsed, and that is not being paid in a timely manner pursuant to an agreement with the authority responsible for collecting the tax liability, unless the Federal agency has considered, in accordance with its procedures, that this further action is not necessary to protect the interests of the Government.”
For the purposes of Section 7073, it is the Department of State’s policy that no award may be made to any organization covered by (1) or (2) above, unless the Procurement Executive has made a written determination that suspension or debarment is not necessary to protect the interests of the U.S. government.
Organizations should be cognizant of the restrictions above when developing project proposals. Funding restrictions require appropriate due diligence of program beneficiaries and collaboration with ISN/CTR to ensure compliance. Program beneficiaries subject to due diligence vetting will include any individuals or entities that are beneficiaries of foreign assistance funding or support. Due diligence vetting will include a review of open-source materials.
Due to the determination made under the Trafficking Victims Protection Act (TVPA) for FY 2025, certain assistance that benefits the governments of the following countries may be subject to a restriction under the TVPA. New determinations will be made for FY 2026 later in FY 2025. The Department of State determines on a case-by-case basis what constitutes assistance to a government; the general principles listed below apply.
Assistance to the government includes:
· All branches of government (executive, legislative, judicial) at all levels (national, regional, local);
· Public schools, universities, hospitals, and state-owned enterprises, as well as government employees;
· Cash, training, equipment, services, or other assistance provided directly to the government, assistance provided to an NGO or other implementer for the benefit of the government, and assistance to government employees.
Subject to TVPA for funds obligated during FY 2025:
AF: Eritrea (partial waiver), South Sudan (partial waiver), Sudan (partial waiver), Djibouti (full waiver) EAP: Burma, Brunei (full waiver), Cambodia (partial waiver), PRC (partial waiver), Macau (partial waiver), North Korea, and Papua New Guinea (full waiver) EUR: Belarus (partial waiver), Russia (partial waiver) NEA: Iran, Syria SCA: Afghanistan (partial waiver), Turkmenistan (full waiver) WHA: Cuba, Nicaragua, Saint Maarten (partial waiver), Venezuela (full waiver) Additional requirements may be included depending on the content of the program.
6. Other Submission Requirements All application materials must be submitted through www.Grants.gov unless you are a U.S. government entity applying for Inter-Agency Agreement (IAA) funding. If you are applying for an IAA please submit proposals to the program team ctrspecialprojectsproposals@state.gov and ISN-CTR-BUDGET@state.gov.
F. Application Review Information
1. Review Criteria Each application will be evaluated and rated based on the evaluation criteria outlined below.
Quality and Feasibility of the Project Idea – 25 points: The project idea is well developed and responsive to the policy and program objective of the NOFO. The applicant describes the project’s potential contribution to solving the problem addressed in the problem statement. The application clearly defines the problem; its’ causes; stakeholders; and existing research/data; the approach taken to solve the problem; realistic milestones to indicate progress.
Organizational Capacity and Record on Previous Grants – 20 points: The applicant demonstrates an institutional record of successful projects in the content area proposed. The applicant demonstrates experience (e.g., has previously worked and/or has established contacts/partners) in the proposed country/territory/region. The organization has expertise in its stated field and has adequate staffing to manage the proposed project.
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