USAID Risk Appetite Statement - June 2018

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U.S. AGENCY FOR INTERNATIONAL DEVELOPMENTRISK APPETITE STATEMENT – JUNE 2018

TABLE OF 3Agency Objectives41.4Risk Categories41.5Risk Appetite Methodology51.6How to Use This Statement62.OVERALL RISK APPETITE STATEMENT63.PROGRAMMATIC RISK84.FIDUCIARY RISK105.REPUTATIONAL RISK126.LEGAL RISK147.SECURITY RISK168.HUMAN-CAPITAL RISK199.INFORMATION-TECHNOLOGY RISK21USAID.GOVUSAID RISK APPETITE STATEMENT 2

USAID RISK APPETITE STATEMENT1.INTRODUCTION1.1PurposeThe purpose of this Risk Appetite Statement (hereinafter “Statement”) is to provide U.S. Agency forInternational Development (USAID) staff with broad-based guidance on the amount and type of risk theAgency is willing to accept – based on an evaluation of opportunities and threats at a corporate level,and in key risk categories – to achieve the Agency’s mission and objectives.This Statement is a critical component in USAID’s overall effort to achieve effective Enterprise RiskManagement (ERM), and the leadership of the Agency will review and update it annually as the ERMprogram matures and our needs evolve.1.2BackgroundIn 2016, the Office of Management and Budget(OMB) updated Circular A-123 to introduce anew requirement that Federal Departments andAgencies integrate ERM with their internalcontrol systems. ERM is a holistic, Agency-wideapproach to risk-management that emphasizesaddressing the full spectrum of risks and managingtheir combined impact as an interrelated riskportfolio, rather than examining risks in silos,which can sometimes provide distorted ormisleading views with respect to their ultimateimpact. Under an ERM approach, the goal isnot to control or avoid all risk, but ratherto take advantage of opportunities, whilereducing or mitigating threats to maximizethe Agency’s overall likelihood of achievingits mission and objectives.USAID.GOVERM AT USAIDAchieving effective ERM is particularly importantat USAID. The Agency’s core mission and role insupport of U.S. foreign policy and nationalsecurity objectives requires that we work in awide variety of high-threat environments, withrisks ranging from state failure and armedconflict in the most “fragile” contexts tocorruption, natural disaster and macroeconomicinstability in more “traditional” contexts. As aresult, there is rarely a single path to achievingdevelopment results, and our staff is called uponevery day to make a range of cross-disciplinary,risk-informed decisions about how best todeliver foreign assistance. Despite these inherentrisks, we rise to this challenge using a variety ofrisk-management techniques because the U.S.Government has made a determination that therisk of inaction, or inadequate action, outweighsthe risk of providing assistance.USAID RISK APPETITE STATEMENT 3

1.3Agency ObjectivesOMB Circular A-123 states that an Agency’s objectives and the context in which it operates shouldinform its risk appetite. On August 7, 2017, USAID Administrator Mark Green articulated the Agency’sobjectives as follows:We will strive to: (1) end the need for foreign assistance. We must measure our work by how far eachinvestment moves us closer to the day when our relationship with the host country changes. In many cases,this day will be far off, but will be a driving force in how we design programs to fit specific needs andchallenges on the ground. To that end, we will focus on (2) strengthening our core capacities and (3)interagency coordination, while (4) empowering our employees and partners to lead. Finally, we will (5)respect the taxpayers’ investments by being transparent and accountable stewards of the resources andexpectations given to us from the American people.USAID’s Mission Statement encompasses these objectives:On behalf of the American people, we promote and demonstrate democratic values abroad, andadvance a free, peaceful, and prosperous world. In support of America’s foreign policy, the U.S. Agencyfor International Development leads the U.S. Government’s international development and disasterassistance through partnerships and investments that save lives, reduce poverty, strengthen democraticgovernance, and help people emerge from humanitarian crises and progress beyond assistance.1.4Risk CategoriesPer OMB Circular A-123, “risk” is defined as the “effect of uncertainty on [an Agency’s] objectives.”This definition is quite different than the everyday use of the word “risk”: it is not necessarily positive ornegative. Rather, it includes factors that could threaten or enhance the likelihood of achieving this set ofobjectives. Using this neutral definition of risk that emphasizes the importance of a continual weighing ofcost and benefit, USAID defines the key categories of risk as follows: Programmatic Risks are events or circumstances that could potentially improve or underminethe effectiveness of USAID’s development or humanitarian assistance. Fiduciary Risks are events or circumstances that could result in fraud, waste, loss, or theunauthorized use of U.S. Government funds, property, or other assets. It also refers to conflictsof interest that could adversely affect the accountability of U.S. taxpayer dollars, or therealization of development or humanitarian outcomes. Reputational Risks are events or circumstances that could potentially improve or compromiseUSAID’s standing or credibility with Congress, the interagency, the American public, hostcountry governments, multilateral institutions, implementing partners, beneficiaries, or otherstakeholders.USAID.GOVUSAID RISK APPETITE STATEMENT 4

Legal Risks are events or circumstances that could potentially improve or compromisecompliance with law, regulation, Executive Order, or other source of legal requirement. Security Risks are events or circumstances that potentially improve or compromise thesecurity of USAID staff, partners, property, information, funding or facilities. Human-Capital Risks are events or circumstances that could potentially improve orcompromise the capacity, productivity, hiring, or retention of employees. Information-Technology Risks are events or circumstances that could potentially improve orcompromise the processing, security, stability, capacity, performance, or resilience ofinformation technology.Encompassing all of these risks is the context inwhich our programs operate. Context is oftenoutside our control, and has the potential tomaterially impact the Agency’s ability to achieveobjectives in a given country. This Statement doesnot assign a risk appetite rating for context.However, since context can often increase thelikelihood that other types of risk might occur(e.g., programmatic, security, fiduciary),understanding context is often the starting pointfor determining an operating unit’s approach torisk-management. For example, while wegenerally cannot mitigate the risk that a conflictmight occur, there are programmatic measureswe can implement to lessen the risk that suchcircumstances affect the effectiveness of ourprograms and operations.1.5NON-PERMISSIVE ENVIRONMENTSContext impacts risk in every environment in whichwe work, but is particularly important in so-called“non-permissive environments” characterized byuncertainty, instability, inaccessibility, and/orinsecurity where the associated risks are higher thanother environments. Such environments are also oftenthe places where development and humanitarianassistance are most needed. Therefore, to achieveour objectives, we often accept a higher degree ofoverall risk to capture opportunities whileimplementing enhanced measures to mitigate thethreat of not achieving our objectives.Risk-Appetite MethodologyIn Sections 2-9, this Statement places each category of risk on a risk-appetite scale that ranges from“low” to “medium” to “high”: Low Risk Appetite – Areas in which the Agency avoids risk, or acts to minimize or eliminatethe likelihood that the risk will occur, because we have determined the potential downside costsare intolerable. These are areas in which we typically seek to maintain a very strong controlenvironment. Medium Risk Appetite – Areas in which the Agency must constantly strike a balance betweenthe potential upside benefits and potential downside costs of a given decision.USAID.GOVUSAID RISK APPETITE STATEMENT 5

1.6High Risk Appetite – Areas in which the Agency has a preference for disciplined risk-takingbecause we have determined the potential upside benefits outweigh the potential costs.How to Use this StatementThis Statement recognizes the reality that frontline staff at USAID is frequently called upon to makedifficult decisions under uncertain circumstances that require a weighing of “opportunities” and“threats.” For example, our staff could see an “opportunity” to strengthen local ownership for longterm sustainability as a “threat” that this sameinvestment could come at the expense of shortterm results, or could result in a larger pipeline.THE RISK PROFILEThis Risk Appetite Statement seeks to clarify theEvery USAID operating unit (OU) must prepareAgency’s position regarding such (oftenand submit an annual risk profile through thecompeting) calculations through the risk appetiteAgency's ERM governance structure, as outlinedrating scale described in Section 1.5.in OMB Circular A-123 and USAIDOperational Policy (ADS 596mab,In addition to providing guidance on how to weigh"Governance Charter for Enterprise Riskopportunities and threats, this Statement informsManagement and Internal Control athow we respond to such risk. Responding to riskUSAID"). These profiles provide a mechanismcan take many forms, including: avoidance of riskto share information on the major risks that faceby not investing in a particular approach or notOUs so leadership has visibility of, and can makesigning an agreement with a particular partner;decisions about, risk across the Agency. Inreduction of risk through a strong system ofaddition, these profiles provide a mechanism tointernal controls, targeted mitigation measures, orensure that the Agency at all levels makes risktraining and capacity-building efforts, among otherinformed decisions. Risks flagged in these profilesoptions; sharing of risk through strategiccould include major risks that require additionalpartnerships with key stakeholders; or acceptanceresponse, or “treatment,” to reduce the threatof risk without mitigation.of loss. Profiles could also include strategic risksthat OUs accept because they have determinedDescriptions of risk-management strategies usedthat the opportunity exceeds the threat of loss.across the Agency appear in each of the “WeIn all cases, assessment of risk and associatedWill” boxes in Sections 3-9. USAID’s Riskrisk response should be guided by this RiskManagement Discussion Note (in Annex 1)Appetite Statement.also lists a range of tools the Agency uses to assistin managing risk. Additional strategies formanaging risks will depend on a local assessment of the likelihood that an individual risk might occur, andthe impact that such risk could have if it occurs. For example, in countries affected by high levels ofcorruption where the likelihood for fraud or diversion of funds is higher than average, we mustimplement enhanced controls to further reduce the likelihood of loss. Conversely, in situations in whichan innovative approach is deemed more likely to be successful, or more likely to have a game-changingimpact, we are more likely to weigh the opportunity presented, and accept the risk.2.OVERALL RISK APPETITE STATEMENTUSAID.GOVUSAID RISK APPETITE STATEMENT 6

The Agency’s risk appetite for each risk category is as follows:RISK CATEGORYOVERALL RISK DIUMLegalLOWSecurityLOWHuman CapitalMEDIUMInformation TechnologyMEDIUMNote: While the Agency’s risk appetite is divided into separate categories, the categories areinterrelated. Additionally, each category contains varying risk appetites for specific areas of focus.Sections 3-9 provide more nuanced guidance on the Agency’s risk appetite for each category.USAID.GOVUSAID RISK APPETITE STATEMENT 7

3.PROGRAMMATIC RISKOverall Risk Appetite: HIGHDefinition: “Programmatic Risk” refers to events or circumstances that could potentially improve orcompromise the effectiveness of USAID’s development or humanitarian assistance.Overview: If we are going to achieve our long-term objective of ending the need for foreign assistance,we must take smart and disciplined programmatic risks. We work in contexts that are often changingrapidly, where – despite our best efforts – evidence to support program design is often incomplete, andwhere there is rarely one path to achieving results. A further complication is that many of the locationsin which the Agency delivers foreign assistance are complex and non-permissive environments (NPEs),in which we are required to navigate higher levels of contextual risk to make effective progress againstprogrammatic goals. In addition, the disciplines of development and humanitarian assistance continue toevolve at a rapid pace, and there are huge opportunities that arise from ongoing innovations that canenable us to achieve breakthrough results. Werecognize all of these opportunities and threats,WE WILL:and are committed to making programmatic Make decisions based on analysis anddecisions based on rigorous analysis, whileconclusions supported by the best currentlyrecognizing that it is often neither possible, noravailable evidence.practical, to achieve the level of information we Incorporate findings from risk-assessments,seek, and that the biggest risks of all are often thesuch as the mandatory climate-change andprice of inaction or inadequate action.construction risk-assessments, in the designof programs.We have a MEDIUM risk appetite with regard Collaborate with a diverse range of partnersto:to leverage innovative thinking that works in Implementing long-term strategic focusthe country context.in our country programs. We will set Evaluate the impact of new approaches topriorities and implement long-term strategiccontinually build the Agency’s evidence base.focus in our country programs based on Work with and through local partners torigorous analysis and collaboration with keystrengthen local capacity and support themstakeholders to achieve more-effectivein their journeys to self-reliance.results. We will also continually balance this Continually monitor, learn, and adapt as thewith our obligation to implement initiatives,context changes and new evidence emerges.directives and/or priorities from Congress Provide rigorous oversight of activities, andand the interagency not foreseen during theensure we always operate in accordancestrategy development process.with applicable laws and regulations.We have a HIGH risk appetite with regard to:USAID.GOVUSAID RISK APPETITE STATEMENT 8

Harnessing new technologies and innovations. We will harness the potential of technologyand innovation to develop responses to some of the most-vexing challenges our Agency faces, whilerecognizing that sometimes these approaches will fail to fulfill their promise. Promoting sustainability through local ownership and resource-mobilization. We willsupport local ownership and financing, and strengthen the capacity of local organizations andsystems to enhance the sustainability of results and the ultimate goal of host country self-reliance,while recognizing that sometimes these investments might be more resource-intensive, or come atthe cost of short-term results. Partnering with the private sector. We will co-design and co-invest with private-sector entitiesthat promise to leverage or mobilize additional resources or expertise to amplify the impact of ourwork, while recognizing that sometimes such partners will fail to mobilize promised capital, ordeliver on commitments. Embracing flexible, iterative design and implementation. We will continually learn andadapt our programming in contexts that are changing rapidly, or in which evidence is incomplete toimprove the likelihood of achieving intended results, while recognizing that such approaches cansometimes require additional resources, or add another layer of complexity in designing,implementing, and monitoring programs. Innovative modalities for acquisition and assistance. We will employ a broader range ofacquisition and assistance methods, such as those that enable co-creation, to achieve ourprogrammatic objectives more effectively, including by harnessing innovations, and partnering withthe private sector and local stakeholders.USAID.GOVUSAID RISK APPETITE STATEMENT 9

4.FIDUCIARY RISKOverall Risk Appetite: LOWDefinition: “Fiduciary Risk” refers to events or circumstances that could potentially result in fraud,waste, loss, or unauthorized use of U.S. Government funds, property, or other assets. It also refers toconflicts of interest that could adversely affect the accountability of U.S. taxpayer dollars, or therealization of development or humanitarian outcomes.Overview: We respect our role as a steward of the resources given to us by the American people, andtake a zero-tolerance approach toward fraud, corruption, or violation of law that involve U.S. taxpayerfunds. We also recognize that corruption, low absorptive capacity, and weak management capacity in thecountry context can increase the Agency’s fiduciary risk, and that we must identify additional measuresas necessary to mitigate this risk. In addition, we acknowledge that there are times when minimizingfiduciary risk by avoiding implementation modalities that use partner-country systems could come at thecost of making progress toward our mission of ending the need for foreign assistance. We are thuscommitted to striking a balance, in coordination with Congress, between our obligation to safeguardU.S. taxpayer funds and our strategic objective to increase local capacity and ultimately transitionpartner countries from our assistance.We have a LOW risk appetite with regard to: Non-compliance with financialreporting, payment mechanisms,financial-systems requirements, internalcontrols and audit-management. We willcontinually act to address any weaknesses inthe control environment that could result infraud, corruption, diversion of resources, orstatutory violations.WE WILL: Implement rigorous safeguards against fraud,corruption, or diversion of funds. Continually maintain, assess, and update oursystems of audit, risk-assessment, andinternal controls. Identify additional mitigation measures asneeded in the country context, such ascomplementary anti-corruptionprogramming or enhanced controls. Implement smart measures that enable morefunding to flow through local partners. Violations of codes of conduct thatinvolve sexual exploitation or abuse andexpose partners or the Agency tofinancial loss. We will hold ourimplementers and our staff to the highestpossible ethical standards, and expect them to protect the interests of beneficiaries.We have a MEDIUM risk appetite with regard to:USAID.GOVUSAID RISK APPETITE STATEMENT 10

Implementing funding through local partners. We will implement more funding through localpartners, including (under the right conditions) host-country partner governments, to enhance thesustainability of results and enable progress toward the ultimate goal of ending the need for ourassistance; however, we must balance this goal with an assessment of the potential for fraud,corruption, or the diversion of funds.USAID.GOVUSAID RISK APPETITE STATEMENT 11

5.REPUTATIONAL RISKOverall Risk Appetite: MEDIUMDefinition: “Reputational Risk” refers to events or circumstances that could potentially improve orcompromise USAID’s standing or credibility with Congress, the interagency, the American public, hostcountry governments, multilateral institutions, implementing partners, beneficiaries, or otherstakeholders.Overview: Our reputation among key stakeholders has a profound and direct impact on our capacityto achieve our mission. It affects everything from the budget and authorities granted to us by Congressto the degree of influence we wield as we work to facilitate greater ownership of developmentprocesses by local partners, including host-country governments. Reputational risk includes risks thatarise from our actual contributions and value, or decisions not to contribute, as well as risks that stemfrom perceptions and misperceptions of our contributions and value. We are therefore committed toprotecting the reputation of the Agency by not only implementing effective ERM in everything we do,but also by effectively engaging and communicating with our stakeholders toward achieving our mission.We have a LOW risk appetite with regard to:WE WILL: Deficiencies in enforcement of ethicalstandards. We will hold our staff andpartners to the highest level of ethical andprofessional standards, and address anyweaknesses in enforcement of rules of ethicalprofessional conduct, including with regard tosexual exploitation and abuse. Deficiencies in Congressionalconsultation and notification. We willaddress any weaknesses in processes,procedures, knowledge, or gaps in eitherrequired or appropriate consultation andnotification to Congress and other U.S.Government Departments and Agencies. Thisapplies to proposed and actual budgetary,management, programmatic, and other actions that could pose a legal and reputational risk to theAgency, or otherwise compromise our adherence to the law and our relations and understandingswith Congress and the interagency.USAID.GOV Maintain an open, transparent relationshipwith key stakeholders. Continue to publish USAID data whilesafeguarding Personally IdentifiableInformation (PII) and security. Appropriately and consistently brand andmark USAID-funded activities. Dedicate time and resources to managingand monitoring social media channels thatare used. Train staff to be everyday ambassadors forour work, and ensure the highest levels ofethical conduct.USAID RISK APPETITE STATEMENT 12

We have a MEDIUM risk appetite with regard to: Traditional press outreach and social media. We will leverage outreach through traditionalpress and social media to promote and amplify the goals and results of the Agency. However, wemust balance this outreach with the risks inherent in these activities, such as messages re-posted byoutside groups or taken out of context.We have a HIGH risk appetite with regard to: Empowering our employees to represent the Agency. We will empower our employeeswith the necessary skills and ability to represent USAID effectively. Sharing and increasing the transparency of technical and programmatic information.Through our Open-Data policy, we encourage employees and partners to share technical andprogrammatic information to demonstrate the Agency’s commitment to transparency, consistentwith applicable legal requirements, while balancing the risk of publishing data that could triggerprivacy and security concerns. We recognize that this commitment to transparency also includesaccepting the risk of possible criticism brought because data show our activities fall short of theirobjectives. Promoting a culture of learning. We will incentivize and foster a culture of learning by openlydiscussing and disseminating lessons learned to enable continuous improvement and enhance ourcredibility. This will mean at times identifying mistakes or errors that could affect our reputation.USAID.GOVUSAID RISK APPETITE STATEMENT 13

6.LEGAL RISKOverall Risk Appetite: LOWDefinition: “Legal Risk” refers to events or circumstances that could potentially improve orcompromise compliance with law, regulation, Executive Order, or other legal requirement.Overview: To be accountable stewards of the resources and expectations given to us from theAmerican people, we must operate in accordance with all applicable laws, regulations, Executive Orders,and other legal requirements. We recognize that the need to comply with legal requirements is inherentin all aspects of our activities, and we are committed to seeking appropriate legal review of our actionsto facilitate this compliance. We are obligated to maintain a strong control system that promotescompliance with legal requirements, and uses Agency attorneys as both a safeguard against unlawfulactions and a resource for informed decision-making.We have a LOW risk appetite with regard to: Non-compliance with legal andregulatory requirements. We will mitigateany weaknesses in processes, procedures, orgaps in staff knowledge that could result inlegal risk to the Agency, or otherwisecompromise our adherence to the law.WE WILL: Deploy training, guidance, and controlsystems to foster Agency-wide compliancewith legal requirements. Monitor changes to applicable legalrequirements, and communicatemodifications to the Agency. Consult with Agency attorneys asappropriate to evaluate, quantify, andmitigate legal risks. Take consistent legal positions that aresupported by the law, represent the bestinterests of the American people, andadvance Agency objectives. Acting without consultation withAgency attorneys. We will consult withAgency attorneys to mitigate the potential formisinterpretation of legal requirements thatcould result in a loss to the Agency, orcompromise our adherence to the law. Meritorious bid protests or labor,employment, or contract claims. We willmitigate any deficiencies in processes or procedures that could increase the likelihood of a sustainedbid protest or meritorious labor, employment, or contract claim.USAID.GOVUSAID RISK APPETITE STATEMENT 14

We have a MEDIUM risk appetite with regard to: Areas either not covered by the law or reasonably open to interpretation. In consultationwith Agency attorneys, we will at times assume a degree of calculated risk to implement innovativesolutions that could help achieve our strategic objectives.USAID.GOVUSAID RISK APPETITE STATEMENT 15

7.SECURITY RISKOverall Risk Appetite: LOWDefinition: “Security Risk” refers to circumstances or events that could potentially improve orcompromise the security of USAID staff, partners, information, funding or facilities.Overview: Safeguarding our personnel, partnerorganizations, information, and facilities is criticalto delivering on our mission, yet presents one ofour biggest risk-management challenges. USAID’swork increasingly takes place in high-threat, NPEscharacterized by conflict, government instability,and natural disasters, and the obligation to keeppersonnel and other assets safe must be balancedwith the need to visit project sites, meet withlocal contacts, consult with partners, accessinformation, and implement activities. We arecontinually working on strategies that reflect thisreality, and we are committed to leveraging newtechnologies, partnerships, flexibilities, andinnovative thinking to protect our personnel andassets, while also delivering needed assistance. 1WE WILL: Continually strengthen controls surrounding We have a LOW risk appetite with regard to: Actions that put our personnel inpositions of unnecessary risk. We willavoid actions that could put USAID personnelat risk of physical harm when and wherereasonable alternatives exist. Violations of information-securitythe collection, processing and storing of vitalpersonal and national security-relatedinformation.Provide staff with regular trainings and travelbriefings (e.g., the Know-Before-You-Gobriefing) so that they appropriately respondto various security threats.Continually strengthen the Partner LiaisonSecurity Operation program in countrieswhere partners are at elevated risk.Leverage highly-qualified local staff, partners,and innovative technologies to monitorprograms in high-threat places wheremobility is restricted.Conduct partner vetting using a risk-basedapproach to mitigate the risk of diversion offunds to terrorists or their affiliates.Continue to engage with the StateDepartment’s Bureau of Diplomatic Security,including Regional Security Officers, tomaximize our ability to conduct robustoversight in NPEs, while safeguardingpersonal security.1It is important to note that USAID’s staff assigned overseas fall under Chief of Mission (COM) authority, andtherefore risk-management approaches are affected by the Overseas Security Policy Board security standards, theRegional Security Office, and USAID's participation in Emergency Action Committees chaired by each Chief ofMission.USAID.GOVUSAID RISK APPETITE STATEMENT 16

policies and procedures. We will minimize any weaknesses in our training protocols or policiesand procedures that could result in the unauthorized disclosure of sensitive data, such as PII andnational-security information. Compliance with nationally-established standards for Federal employment and securityclearances. We will address any weaknesses in compliance with standards for Federal employmentand security clearances that could compromise the Agency’s ability to recruit and retain qualifiedpersonnel who have unwavering loyalty to the United States as well as integrity and soundjudgement.We have a MEDIUM risk appetite in regard to: Maintaining presence in non-permissive environments (NPEs). We will maintain missionsor field offices in NPEs as long as we balance the likelihood for security breaches and/or need tosuddenly evacuate staff or allocate additional security resources with the NPE’s impact on U.S.foreign-policy and national-security objectives. Programming in a transparent manner in closed spaces. 2 We will operate with as muchtransparency as possible in closed (or closing) spaces, while balancing the imperative to protectpartners and beneficiaries who could face significant risks from association with the United States. Undertaking mission-critical field visits. We will support staff in undertaking field visitscoordinated and approved in accordance with Post management policies and Regional SecurityOfficers (RSOs) for the purposes of de

1.6 how to use this statement 6 2. overall risk appetite statement 6 3. programmatic risk 8 4. fiduciary risk 10 5. reputational risk 12 6. legal risk 14 7. security risk 16 8. human-capital risk 19 9. information-technology risk 21

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