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InterAction is the largest alliance of international nongovernmental organizations (NGOs) in the U.S., with nearly 190 members working in every developing country. Members are large and small, faith-based and secular, with a focus on the world’s most poor and vulnerable populations. The U.S. public, foundations and governments support the work of our members who collectively invest and manage over $18 billion a year. InterAction’s own funds come from dues and generous grants from others, such as foundations, corporations and governments. Using its collective voice, InterAction seeks to shape important policy decisions as wide range of foreign assistance, relief, development, environmental and other issues that advance human dignity.
About The Position
Position: Analyst, USG Regulatory Risk and NGO Response
Position Type: 3 Months (October-December 2018)
Location: Washington, DC
Travel: Domestic (within Washington, DC)
Reporting to: VP, HPP
Reporting to the VP, Humanitarian Policy and Practice, the analyst will work alongside numerous colleagues including the VP for Global Development Policy and Learning, Director for Humanitarian Practice, the Legislative Manager for Humanitarian Affairs, the Manager for Democracy, Rights, and Governance Initiative, as well as with member NGOs concerned with the increasing regulatory environment. Externally, this position liaises with InterAction members, the Charity & Security Network and other similar groups, as well as with USG offices that oversee regulations, including but not limited to USAID, the Departments of State and Treasury, Offices of the Inspector General, and the US Congress. Depending on progress, the analyst may also dialogue with other non-USG donors to further comparative points within the research.
Purpose of project
Donors are under increasing domestic pressure to justify and safeguard the use of development and humanitarian funds, with the potential risk of programs and budgets being reduced if adequate assurances cannot be provided against regulatory parameters. Both donors and aid organizations face considerable scrutiny over fraud, safeguarding and counter-terrorism issues, and have low levels of tolerance for any such systems failures. Risk, and the way it is experienced and shared differently by government donors and their NGO partners is growing into a barrier towards finding common solution to the increasing pressures. These pressures include but are not limited to OIG regulations, bank de-risking, partner or beneficiary vetting, and counter-terrorism legislation.
Within the humanitarian sphere, the result of additional conditionalities include: increased time needed to obtain funding to respond; decreasing adaptability in highly complex and volatile operational environments, as well as in more risk-averse programming and priority setting by agencies; tightly earmarked funds with narrow programming windows; decreased utilization or remote management and/or partnership arrangements; private funds being used to cover costs of extensive compliance mechanisms; and the limited availability of flexible and multi-year funding to ensure program continuity.
For the broader development sphere, the increasing regulatory environment threatens to decrease civil society’s ability to operate independently. Furthermore, some regulatory measures of growing concern to the NGOs were not designed for them or their operations, yet outdated definitions and stricter enforcement could ensnare NGOs. These include bank de-risking measures, and new legislation connected to the Foreign Agent Registration Act (FARA) of 1938. Efforts to remove exemptions or retain unclear language may further impact non-profits.
The analyst will explore what policies, procedures and guidelines are in place, and for what reasons, mapping out clearly the various measures by different USG offices to regulate NGOs’ operations and finances. Additionally, the research will need to include the impact of current external threats to NGOs, such as the recent case brought against NPA by a private citizen, using USG laws.
Members have taken on different responses to the current shifting environment, with some standing up compliance units, and other tracking as best they can how to protect their organization. There is a need to educate ourselves on what is being asked of us, and who is doing what, where, why and how. Additionally, we need a common language, based on evidence, of the cost of the regulatory environment, including clarity on in what other areas of its foreign assistance portfolio the USG is willing to accept risks and why.
This position is intended to serve as a temporary surge, building on the existing capacities of InterAction staff and members to aid us in defining the current landscape, and building out recommended next steps for InterAction and its members.
Desired outcome and key activities
InterAction members gain a broader understanding of regulatory measures in place, and their impact, and define a collective strategy for mitigation efforts. To achieve this outcome, the consultant will work with InterAction members and other stakeholders to:
- Conduct a comprehensive mapping, and accompanying analysis to include trends and impacts of the USG regulatory environment as its impacts on international NGOs and their operations, to include the expertise and concerns of NGOs and government officials, forecasting of future legislation or donor guidance, and identifying upcoming opportunities for briefings and educational meetings with relevant stakeholders.
- Develop a best practices / options guidance note on how NGOs are responding to the regulatory environment, attentive to the diversity of operations and size amongst NGOs. Supporting materials may include interviews, review of NGO procedures, and media reports.
- Coordinate and facilitate educational briefings and meetings with NGOs on the results of the mapping exercise, leading into the development of proposed next steps.
- Draft an “after action” review to document successes, challenges, and lessons learned from this process.
- 7-10 years professional experience in development/humanitarian operations, including an understanding of USG compliance environment;
- Strong understanding of INGO sector and the USG donor environment;
- Proven analytical skills, with demonstrated ability to identify consequences and potential implications for NGOs and their operations of regulatory mechanisms and actions;
- Excellent written, organizational and verbal communications skills, including presentation experience;
- Strong interpersonal skills and experience managing and representing the interests of diverse constituencies;
- Demonstrable commitment to a collaborative approach;
- Master’s degree in a relevant field or equivalent work experience;
There are no extraordinary physical requirements for the performance of the essential functions of this position. InterAction will make reasonable accommodation to enable individuals with disabilities to perform essential functions.
Minimum Education Required
How To Apply
Please email your resume and cover letter to firstname.lastname@example.org with subject line containing: Analyst, USG Regulatory Risk and NGO Response. Position will remain open until filled but applications received before 27 September 2018 are preferred. Due to the expected volume of applications, only finalists will be contacted.All applicants must be able to provide documentation that they are legally eligible to work in the United States for an extended period of time. No phone calls please.