The OECD differentiates three overlapping categories of risk that aid interventions in fragile situations need to consider and monitor: contextual, programmatic and institutional risks. Contextual risks are factors over which external actors have limited control – like the risk of state failure, progress or failure of a peace process, military interventions, and humanitarian crisis. Programmatic risks focus on the failure to achieve aims and objectives, and the risk of causing harm through intervention. Institutional risks are risks to the aid provider that arise mostly out of programmatic risks. These are typically expressed in terms of (in)security, fiduciary failure, reputational loss and domestic political damage.[13]

As contextual risks are mostly outside the control of aid interventions, and cannot be directly influenced by programming, most donors focus their risk management and mitigation strategies on the combination of programmatic and institutional risks (the so-called aid risks). However, contextual risks should be considered as they affect programmatic and institutional risks – and hence all three risk categories should be closely monitored. The OECD points out that risk management is not just about risk reduction or avoidance: it’s about balancing risk and opportunity, and balancing control and flexibility.[14] Engaging in conflict settings demands a significant degree of risk taking, which in turn requires programming to be based on solid analyses and continuous monitoring.[15]

For this study, we focus specifically on the monitoring of programmatic fiduciary and accountability risks, as these can be most directly addressed in programme design. There is no standard framework or checklist for programmatic risk, as the main risks encountered in conflict settings depend on the nature of the activities being implemented. For example, activities involving a significant volume of material goods, such as constructing a police station or delivering food aid, run a high risk that funds and equipment will be diverted. Nevertheless, projects without significant funds and materials, for instance dialogue or training programmes, can still see corruption and diversion, albeit typically to a lesser extent, for example in the form of corrupt selection processes for event invites (e.g. nepotism).[16] Given these differences, table 2 below provides an overview of the most common programmatic risk categories along with specific risks and examples from Afghanistan, Somalia and Syria.

Table 2
Programmatic fiduciary and accountability risks to donors and implementing organisations in conflict settings

Risk category

Specific risks involved

Example from case studies

Diversion of funds

- Ransom

- Checkpoint payments

- Informal taxes

- Corruption

Having to pay ‘taxes’ to both (local) government and informal groups like Al-Shabaab to transport food aid from Mogadishu port at multiple checkpoints.

Diversion of equipment

- Appropriation by armed groups

- Unauthorised sale

- Theft

Constructing an airstrip in a territory later taken over by Al-Shabaab; tens of Humvees in Afghanistan that simply ‘go missing’.

Diversion of activity

- Corrupt selection processes for event and training invites

Hosting an event that is hijacked by a certain family or clan to the detriment of the intended beneficiaries.

Co-optation of counterpart

- Use aid activity as front for other activities

- Infiltration by replacing key staff with stakeholders in conflict

Security staff hired for the project can be part of a local militia with an active stake in the conflict.

Non-delivery of outputs but claiming funds nonetheless

- Forged paperwork proving delivery

- Delivering a minor part without ability to monitor the whole

Without the ability to directly check the projects, donors must rely on the word of their partners. This can lead to conflicting reports on the progress of projects. Only during field trips conducted much later on is the ongoing deception discovered.

Partner is unknowingly affiliated with reputationally damaging groups

- A local partner (individual or group) is somehow affiliated with an internationally designated terrorist or other blacklisted group

Organisations in Afghanistan, Somalia and Syria mentioned that different donors have blacklisted different groups, which presents challenges. For example, in Syria EU donors agree to work with Kurdish partners, but Turkey does not. This lack of consensus is especially problematic when there are multiple donors or donors change. Similarly, groups first greenlighted for cooperation can later be listed as terrorist organisations (e.g. the Nour al-Din al-Zenki movement was once seen as a moderate group in the Syrian civil war and received US support, but later was involved in atrocities).

Misalignment of programme and local needs

- Goods and services provided are not used, leading to wasted resources

- The decision to provide certain goods and services may be influenced by contractors seeking profits rather than being based on a needs assessment

In Afghanistan the US army spent USD 468 million on transport aircrafts that were unused because maintenance was difficult. The aircrafts were left to rust on a runway and were eventually sold for USD 32,000 as scrap metal.

Looking at table 2, what becomes clear is that regardless of the type of project, there are numerous risks for aid activities, including failure to achieve ‘value for money’, funds and assets ending up in the hands of conflict parties, and the reputation of a donor or its implementing partner being damaged.

As indicated in the introduction, there are many other risks related to programme implementation in addition to key fiduciary and accountability risks. These relate mostly to effectiveness, including divergent national interests and politically sensitive information increasing donor competition or blocking adequate coordination, and also to meaning, including inadequate conflict analysis or an incorrect understanding of the local political economy. Such risks are discussed elsewhere.[17]

In addition to these programmatic risks, there are unique challenges to monitoring in situations of conflict that are summarised in table 3 below.

Table 3
Monitoring challenges in situations of conflict

Challenge category

Specific challenge involved

Example from case studies

Remote management and lack of physical access due to security risks

- Restrictions on (staff) field visits

- Scope for visiting often limited

- Reliance on single sources of information

- Limited community engagement

- Limited understanding of wider impacts[18]

Most organisations interviewed did not have staff on the ground but relied on other parties with occasional staff field trips (usually very short and limited to heavily guarded locations like hotels and embassies).

Low capacity of implementing partners to monitor (see 4.2.1)

- Implementing partners cannot provide proper monitoring (e.g. no receipts and no paper trail)

Some implementing partners in Somalia did not have the capacity to provide financial records at the start of the programme and had not worked with receipts before.

Low trust in implementing partners to truthfully monitor

(see 4.2.1)

- Implementing partner deliberately misinforms donor

- Monitoring reports are ignored because they cannot be fully trusted

Organisations in Afghanistan, Somalia and Syria all reported that monitoring information informed decision making when it was trusted; however, when there was little trust (as was often the case at the start of a new relationship) information was collected but frequently not used.

Reliance on a third-party monitor (TPM)

(see 4.2)

- TPM may not have the capacity to properly carry out monitoring

- TPM often runs into same security restrictions as implementing partner

- TPM may not be entirely impartial and may have a conflict of interest

- TPM may damage relations with the implementing partner or the local community

TPMs in Somalia were reluctant to leave the big cities and put heavy demands on the implementing partners.

The impartiality of TPMs in Syria was questioned and they have on occasion acted in conflict-blind ways and damaged relations with the local community.[19]

Reliance on remote monitoring with technology

(see 4.2.3)

- Technological approaches are susceptible to systematic bias or errors

- Can be capital intensive and require steep learning curves as well as creating new security concerns

- Issues with data verification, interoperability, privacy and interpretation

One organisation specifically requested that their partners use satellite phones, but the expensive and conspicuous equipment turned the users into targets and the local staff using it felt less safe than without the satellite phones.

Lack of trustworthy existing data

- Some information is politically sensitive and therefore unavailable

- Data is politically sensitive and therefore has been manipulated

- No baseline data

Population data in Somalia is politicised, as funding given to regional states by donors can be tied to population size.

Intangible variables

- The variables that one tries to change (such as legitimacy or security) are intangible and difficult to measure

Organisations working on the peace process in Somalia through dialogue training struggle to accurately measure ‘value for money’.

As table 3 highlights, the main challenge of monitoring in conflict situations is the reliance on information by others. This reliance is problematic because of technical challenges (e.g. does the partner organisation have adequate (financial) capacity, is the technology used the appropriate one, has data been gathered?), as well as issues of trust (e.g. is the partner organisation trustworthy, is the data accurate, does the TPM have a conflict of interest?).

OECD (2012), Managing Risks in Fragile and Transitional Contexts: The Price of Success?, Paris: OECD.
Ibid.
Programming should be designed based on a sound political economy or conflict analysis and take conflict sensitivity into account. For more information on conflict sensitive programme design see, for example: link or link
Clingendael interviews with non-governmental organisations (NGOs) in Somalia and Syria, May-June 2018.
In particular, the Development Leadership Programme (link), Political Settlements Research Programme (link) and Thinking and Working Politically (link) discourse offer valuable insights, case studies and experiences.
Independent Commission for Aid Impact (2016), DFID’s approach to managing fiduciary risk in conflict-affected environments – A performance review, London: ICAI, p.31.
Building Markets (2018), What is the point… if nothing changes? Current Practices and Future Opportunities to Improve Remote Monitoring and Evaluation in Syria, New York: Building Markets, p.22.