An Analysis of Contemporary Anti-Diversion Policies and Practices of Humanitarian Organizations



Humanitarian organizations have long developed internal policies and practices to help ensure that aid and assistance reach intended beneficiaries. By identifying and examining contemporary anti-diversion policies and practices of humanitarian organizations, this report aims to document, contextualize, and analyze how those organizations are currently approaching and responding to increasing donor and public scrutiny regarding particular fields of concern—namely, bribery, corruption, fraud, money laundering, and terrorism financing.

This report was written with three general audiences in mind: humanitarian organizations (especially legal and policy advisors, grant officers, compliance officers, and regional and national coordinators); donors (especially general counsel, policymakers, and grant officers); and beneficiary communities. The various parts of the report may be of more or less interest to the different audiences. This report is intended to be read alongside the CHE Project’s report on contemporary counterterrorism-related clauses in humanitarian grant and partnership agreement contracts.

The Executive Summary provides a high-level overview of the main research elements, observations, and findings of the report by excerpting the most salient portions. The Glossary defines the key terms used in the report, and the Acronyms section explains the abbreviations employed in the report. The Methodologies section outlines what types of research and evidence—including interviews, on the phone and in person (in Geneva, Nairobi, New York, and Washington, D.C.), desk research, and other stakeholder engagement—underlies the report.

The Introduction and Context section describes the impetus for this research project, and briefly defines the three general fields of anti-diversion concern: anti-bribery and anti-corruption; anti-fraud and anti-money-laundering; and anti-terrorism-financing. The section sketches some of the broader themes, topics, and trends in the humanitarian sector and in the anti-diversion domain, highlighting, for example, the expansion and decentralization of humanitarian organizations; perceptions that certain donors have a disproportionate impact on standards-setting; and growth in the complexity, scope, and number of anti-diversion regulations and enforcement bodies.

Against the backdrop of the previous section, the Anti-Diversion Policies and Approaches section outlines some of the most salient characteristics of humanitarian organizations’ contemporary anti-diversion policies and practices identified in the research. One of the key findings is that, in line with their central objective, humanitarian organizations have long developed internal policies—including through program design, risk assessment and analysis, and monitoring and evaluation—aimed at ensuring that aid and assistance reach intended beneficiaries. The section discusses both internally developed policies and those imposed by external sources. The section then explores how anti-diversion policies are formulated, disseminated and inculcated, and enforced.

The Observations section identifies four interrelated sets of anti-diversion trends and trajectories identified during the research, exploring frameworks and threshold concerns; the multiplicity and complexity of anti-diversion policies; engagement with donors and other stakeholders; and organizational structures, cultures, and resources. The Conclusion briefly notes that with rising pressure from legal and regulatory mechanisms, humanitarian organizations are devoting more resources to the administrative, policy, operational, and legal components of anti-diversion compliance. And they are doing so, in many respects, with fewer resources and under increasingly greater scrutiny from donors and the media.

The Bibliography lists the sources cited and many of the sources reviewed for this report.
Finally, the Annexes provide excerpts of resources identified during the research, including examples of risk assessments, internal guidance on screening software, and fraud indicators.