Many of the world’s 40,000 International NGOs (INGOs) work in places where terrorist financing, sanctions breaches, and diversion are key risks. Almost all of the top ten recipient countries of humanitarian aid alone in 2015 were high-risk jurisdictions, for example, receiving more than £7bn between them. When they feel safe to speak, sector workers share sobering stories about what might have happened to some of this money.
As INGOs struggle to keep up with worsening humanitarian needs, diversion risks and their complexity remain daunting. The demands of internal stakeholders, donors, banks, and regulators are diverse and even contradictory. Public scrutiny has magnified, but is not always well-informed. Institutional donors transfer ever more risk to implementing partners, while some banks seek to avoid this business altogether, pushing some NGOs outside the global banking system. Looming over all of these converging pressures is a latticework of austere international sanctions and counter-terror regimes.
It is no surprise that INGOs find themselves struggling to reconcile this complex set of expectations with their charitable missions. Yet the consequences of failing to do so can be severe; future funding is contingent on reputation, and serious offences litter the regulatory landscape. The implications of breaches can be existential for organisations and criminal for individuals.
Terrorist Diversion: A Guide to Prevention and Detection for NGOs is an accessible, pragmatic guide for international NGOs of all shapes and sizes. Clearly explaining the nature of the challenge, and setting out a programme to meet it, it explores how it is possible for INGOs to manage these risks more effectively through their missions – not in spite of them.
Table of Contents
1. The Challenge: Terrorist Diversion and INGOs
2. The Myths: Common Misconceptions
3. The Rules: International Standards and Law
4. The Risks: How Diversion Occurs and What it Looks Like
5. Principles and Approaches: Introducing an Anti-Diversion Programme (ADP)
6. Risk Assessment
8. Due Diligence
9. Detection and Response
10. Culture, Communication and Training
11. Leadership, Governance and Management
12. De-risking: The Intersection of a Bank’s AML/CTF Programme and the INGO
13. Working in Partnership
Oliver May is a Director at Deloitte Australia. Formerly the head of counter-fraud for Oxfam GB and an investigator with Britain’s Serious Organised Crime Agency, he has helped aid organisations worldwide to manage the risks of fraud, corruption, terrorist financing, and money laundering.
Paul Curwell is also a Director at Deloitte Australia. He was formerly the global lead for intelligence and due diligence investigations at Australia’s largest bank, and has almost 20 years’ experience in risk management, specialising in financial crime, security, and due diligence.
"This is a thorough and important exploration of an intractable problem. For too long, the international community has struggled to apply the nuance required to devise a framework for addressing the risk of aid diversion. This book responds effectively to that shortcoming." - Tom Keatinge, Director, Centre for Financial Crime and Security Studies, RUSI
"There are no easy answers to the risk that the money will not get through to those that need it most. This excellent book will guide not only charities, but other stakeholders in responsible and compassionate aid and development." - Murray Baird, Charity Adviser and former Assistant Commissioner General Counsel, Australian Charities and Not-for-profits Commission (ACNC)