FY 2023 Risk Analysis Template.docx

RISK ANALYSIS TEMPLATE

Note: Instructions, suggested format examples, helpful links, and table examples should be deleted from your submission.

Instructions The purpose of the risk analysis is to identify the internal and external risks associated with the proposed program in the application, assess the likelihood of the risks, assess the potential impact of the risks on the program, and identify actions that could help mitigate the risks. A risk analysis should not be considered a one-time exercise or a static document. PRM expects partners to conduct risk analysis and remediation throughout the life of a program, as well as revise risk-related documents and processes, and promptly share updates with PRM. The safety and security of recipients and program participants are of utmost importance. PRM requires all recipients to conduct thorough risk assessments and take all actions necessary in accordance with those assessments to mitigate those risks.

The annex should assess the risk for fraud, waste, and abuse associated with the proposed program including, but not limited to the categories in the table below.

The annex should describe risk mitigation strategies (including for any sub-recipients) to include conflict of interest policy, whistleblower procedures, ethics training, cyber/digital security, and data protection procedures, including how organizations protect program participants’ personal data broadly and in the given local context, banking protocols, procurement and logistics policies, and human resources policies.

The risk analysis annex should also describe and include any additional risk mitigation procedures including:

Reviews of publicly available information regarding the behavior of sanctioned groups and individuals.

Sanctioned group movements, to include maps.

Searches of public databases, including SAM.gov, the Department of the Treasury’s Office of Foreign Assets Control’s (OFAC) Specially Designated National List, UN Security Council Sanctions List, the Department of State’s Designated Foreign Terrorist Organizations (FTO) list, etc.

Third-party assessments of risk mitigation policies and procedures.

Suggested Format A suggested format for a risk analysis document is below. Applicants should include all assumptions and external factors identified in the logic model in the risk analysis. Under “Description of Risk,” the risk analysis must address any risk of fraud and corruption, as well as assess the level of risk that the proposed program may inadvertently benefit terrorists or their supporters. Under “Likelihood of Risk” and “Potential Impact of Risk,” applicants must rate them as “High,” “Medium,” or “Low.”

of Risk Potential Impact of Risk Risk Mitigation Plans/Actions

Example:

Sexual exploitation and abuse

Example:

COVID-19

PRM recognizes that programs operating in certain environments provide an increased risk of fraud, waste, abuse, and diversion including from the presence of groups and individuals sanctioned by the U.S. government (USG) under Material Support statutes and/or sanctions programs administered by the U.S. Department of Treasury Office of Foreign Assets Control (OFAC). Applicants should provide additional information regarding safeguards and risk mitigation strategies where these conditions exist. The annex should include details on the applicable prevention measures including:

An analysis of the operating environment in the area(s) in which the organization proposes to work, including identification of sanctioned groups and individuals that have a presence in or maintain control over such areas and how those groups and individuals operate vis-à-vis humanitarian partners and programming.

Are there applicable sanctions programs (e.g., Afghanistan-Related Sanctions, Syria, Global Magnitsky, Counter Narcotics Trafficking Sanctions) in your targeted geographic areas that may pose a risk to your programming activities or that may result in a violation of sanctions? If sanctions programs pose a risk to your programs What risk(s) do they pose, and what is the potential effect(s) on your program?

Would your program require a specific license from the Department of the Treasury’s Office of Financial Assets Control?

An explanation of the safeguards the applicant intends to put in place to prevent interference or influence by, transactions with, or provision of benefits to groups and individuals sanctioned by the USG during all phases of program implementation, including but not limited to the following:

How the applicant will prevent direct or indirect benefits to sanctioned groups and individuals through commercial activities that result in the payment of taxes, fees, tolls, etc., to a sanctioned group or individual.

Risk mitigation plans for moving equipment or supplies into proposed areas, including whether a sanctioned group could potentially benefit from fees or taxes paid during any stage of program implementation or could seek to divert equipment or supplies.

Measures to mitigate the risk that a sanctioned group would receive reputational benefit from the proposed program, such as a sanctioned group claiming credit for the assistance or services provided.

How the applicant will respond to attempts by sanctioned groups and individuals to interfere with or influence the way the applicant carries out program activities. The applicant should clearly articulate triggers for action and specify organizational processes for decision-making.

How participant and recipient targeting, and registration ensures that program beneficiaries are not sanctioned group members or affiliates.

How the applicant will verify that assistance reaches the intended participants.

How the applicant ensures that program assistance is not diverted from intended participants and recipients following distribution or service.

The controls and systems the organization must ensure that procurement and hiring do not benefit sanctioned groups and individuals.

Any additional internal controls and oversight mechanisms the organization will put in place.

Helpful Links General Services Administration’s System for Award Management (SAM) U.S. Department of the Treasury OFAC Resources UN Security Council Sanctions List U.S. Department of State Foreign Terrorist Organizations (FTO) Designations