Date: Wednesday, December 17, 2025
Category: Due Diligence
What the Sector Told Us: The Top 5 Due Diligence Priorities and Resources in the Epstein File Landscape
By Courtney Cutler, Catherine Flaatten, and Lindsey Nadeau
Our recent Apra Pulse Check webinar on nonprofit due diligence–sparked by the rapidly approaching release of the Epstein files–did more than sell out. It surfaced something deeper: a sector that knows this moment is pivotal and wants practical, actionable steps to get ready.
Across over a hundred participants and dozens of breakout rooms, five themes emerged, underpinned by concrete steps prospect development professionals can take now. Below is a recap of those themes and action items, including why professionals across the sector said they matter. To help equip you, Apra’s top 5 Due Diligence resources are also linked below for easy reference.
THE TOP 5 THEMES & SUPPORTING ACTIONS
Theme 1: Build Strong Due Diligence Structures, Rubrics & Checklists
Participants agreed: without standardized frameworks, policies, and risk rubrics, even minor concerns can spiral into reactive crisis decisions.
Supporting Action: Add the Epstein Files to Your Public Disclosure List to Review for Each Due Diligence Assessment
Depending on the level of information disclosed therein, prospect development professionals should add the Epstein Files to their checklist of resources to consult when vetting prospects. This checklist also typically includes publicly available resources such as U.S. Treasury Sanctions Lists, U.S. Customs list of blocked/denied/debarred persons, Blocked, Denied, Entity and Debarred Persons Lists, The System for Award Management Exclusions List, etc. This step future-proofs your due diligence reviews as you assess risk moving forward.
Theme 2. Proactive Steps Nonprofits Can Take Now
Attendees want concrete, immediate actions, including triage plans, news alerts, and workflow alignment so that the December 19 file release does not catch their organizations flat-footed.
Supporting Action: Build a “First Wave” Plan for Triage When Names Are Released
When creating a plan for the Epstein files, determine who is responsible for identifying individuals, what risk criteria will be applied, how to document decisions, and when to escalate to leadership or the organization’s decision-making body. Remember that appearance in the files alone may not indicate wrongdoing, and not all philanthropic associations carry the same level of risk. Risk should be categorized as low, moderate or high (or proceed v. do not proceed) depending upon the nature of both the appearance in the files and the individual’s engagement with the institution to ensure efficient resource allocation, strategic decision-making, and clear outcomes that are aligned with organizational values.
Theme 3. Centralized Tracking & CRM-Based Documentation
A consistent pain point: due diligence information often lives in inboxes and spreadsheets. The field is hungry for CRM-based systems that respect donor data privacy, preserve institutional memory, and support defensible decision-making.
Supporting Action: Create or Strengthen Policies and Configurations for Tracking DD in the CRM
This idea directly addresses one of the biggest operational gaps identified in our earlier article: documentation. If due diligence decisions aren’t searchable, auditable, or centralized, an organization is vulnerable long after the news cycle passes. Participants want to move beyond informal notes and toward a system that preserves decisions institutionally. Customize or configure your CRM to track due diligence requests, assessments, and decisions, while ensuring that only appropriate staff with a business need can access confidential information. If constraints prevent customizing or configuring your CRM, document through data governance processes how prospect development will leverage an existing module in your CRM to track basic data (e.g., contact reports, notes, plans, strategies, or disqualification mechanisms or attributes) and save detailed due diligence dossiers in confidential folders of your document storage system.
Theme 4. Governance, Leadership Buy-In & Decision Authority
Organizations want clarity around who makes decisions in high-risk situations, how those decisions are reached and documented, and why leadership alignment is essential.
Supporting Action: Reinforce Why Due Diligence Is Needed; Build Buy-In Now
Due diligence is not sustainable without leadership support. This current event could have major implications for prospects and donors at your organization. Creating a process now can prevent major setbacks later. Use this moment to educate leadership and fundraisers on why structure, consistency, and transparency matter—not just for risk mitigation, but for donor trust, and institutional integrity, and staff protection. And now is an ideal moment to engage leadership to build buy-in if you do not yet have a process in place.
Theme 5. Cross-Team Coordination & Communication
Prospect development cannot and should not carry this alone. Participants emphasized the need for alignment across fundraising, legal, communications, leadership, donor relations, and programmatic units.
Supporting Action: Coordinate Across Departments, including Legal, Communications, Frontline Fundraising, and Donor Relations
The prospect development sector has learned that reputational risk cannot be managed by us alone. Participants expressed the need for shared ownership and alignment before the headlines break, not while a crisis is unfolding. Clarifying project roles before the file drop is essential. Setting up a privileged rapid response communication space with your legal or compliance team in your enterprise chat program (Slack, Teams, Zoom Chat, etc.) or document storage files in a way to quickly flag that you need review and alignment will be essential. Working with public relations or donor relations on an organization-approved message, if donors inquire about your due diligence process or implicated stakeholders, will keep all external messengers aligned. This should be shared not just with frontline fundraisers but also donor services colleagues who field inbound calls from constituents. Update the fundraising division about the high-level plan so they aren’t wondering. Keep in touch with them if their donor is identified in the files, and whether it was a vague association or implied misconduct.
Apra Due Diligence Resources
If you’re building or refreshing your due diligence process, Apra offers many invaluable resources. We have rounded up the best options for you to consult.
1. Apra Blog Post “The Epstein Files Are Coming — Seize This Moment to Shore Up Your Due Diligence.”
2. Apra’s Due Diligence Toolkit
3. Apra’s Plug In to Due Diligence Event Recordings
4. Apra Best Practice in Due Diligence (George Tabet and Carolyn Vasquez)
5. Apra University Webinar: What's Your Red Flag? Reputational Risk and Philanthropic Due Diligence Best Practices (Gareth Griffin and Charles Latham)
Why This Matters
If the Epstein files release anything unexpected, nonprofits will need more than concern. They’ll need structure, alignment, and confidence in their processes.
These top-voted ideas, and the themes behind them, reinforce the core message of our original article: Strategic readiness is not optional. It is an ethical responsibility.
Participants told us that the sector is willing and eager to strengthen its due diligence muscles. Now is the moment to turn that momentum into durable, defensible systems that protect our missions long after this news cycle fades.