ABSTRACT
‘Risk’ and ‘compliance’ appear in both risk-based and compliance-based approaches. The risk-based approach can also be applied by donors, through avoiding lengthy, detailed screening obligations and instead requiring the existence of a risk-based Anti-Diversion Programme in their partners. A risk-based approach is the only way to fully respect the unique disposition of the International Non-Government Organisation (INGO), each country programme, different aid modalities, and every project. Proportionality is about incurring the minimum disruption to business in order to modify diversion risk to an acceptable level. A risk-based approach is a way forward. The principle of proportionality helps to ensure that spending on business support is as little as possible, while risk assessment ensures that it is as much as necessary, spent as effectively as possible. The controls prescribed do not necessarily derive from the risks borne by the INGO, but the donor.
