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Being a Good Partner to USAID: The Importance of an Effective Ethics and Compliance Program to Mitigate Risk of Disallowances, Investigations, and Debarment

By Robert Nichols, Annie Kim, and Steve Shaw

January 22, 2020

This White Paper which is based on input provided by the United States Agency for International Development (“USAID”) and several of its for-profit and not-for-profit Partners is designed as a resource for USAID Partners to develop ethics and compliance programs tailored to the requirements and expectations of their primary funder.

As one of the world’s largest funders of development and relief goods and services, USAID offers tremendous opportunities for its Partners and beneficiaries.  The last decade, however, has demonstrated that USAID’s Partners must also appreciate the unique compliance risks associated with accepting Federal funding and operating in some of the most volatile and unstable environments in the world.  Partners have faced criminal and civil liabilities as a result of regulatory violations, and in some notable instances, faced suspension and debarment for failing to develop adequate internal controls to deal with the risk of fraud and non-compliance.  Organizations have also fallen under greater scrutiny when it comes to counter-trafficking in persons (“C-TIP”) and sexual exploitation and abuse (“SEA”) failures.  Perhaps more so than ever, USAID Partners should take the necessary steps to develop a ready and capable ethics and compliance program.


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