Compliance Consultancy

  • Senior-level, Short-term contract assignment
  • Posted on 2 February 2021
  • Worldwide
  • Closing on 4 March 2021
  • Current
  • Annual gross 12000 - 15000 Pound Sterling

Job Description


The United States Agency for International Development (USAID), the United States’ primary government agency responsible for providing civilian foreign aid, has been the largest single country supplier of Official Development Assistance (ODA) in the world over at least the past two decades. USAID supports development projects in more than 100 countries and its programs and policies have a strong influence on national, regional, and international development agendas the world over.

In 2005, ActionAid commissioned a Scoping Study on funding USAID and US Government sources, to decide whether ActionAid should pursue this funding. ActionAid took a policy position that the organization, its affiliates, associates, and country programs, should only seek direct funding with international director level approval on a case-by-case basis, in Africa region. The primary considerations in reaching these case-by-case decisions include: political and reputational risk; alignment of proposed funding opportunity to AA strategic objectives; capacity to fulfil the complex USAID grant requirements; and capacity to prepare a high quality application and prospects for success. Asia and the Americas imposed a complete moratorium on accepting USAID funding. A follow-up desk review in 2016 reiterated that position.

The main reasons for the decision were: the high compliance and administrative burden of managing USAID funding; the apparent inconsistency between ActionAid’s proactive solidarity with the poor on one hand, and the USA’s active pursuit of anti-poor policies on the other; USAID policies on promoting US corporate interests, limiting sexual and reproductive health work, and preferring US suppliers; and the reputational risk for ActionAid of accepting USAID funding.

In 2020 ActionAid International commissioned a consultant to review ActionAid’s policy on USAID funding, and provide detailed options on any relevant changes to ActionAid’s policy on USAID funding.

The review recommended that ActionAid “allow ActionAid Affiliates to make their own decisions whether or not to pursue USG funding if they decide that it will best support the achievement of their strategy and objectives. ActionAid Affiliates could take an ad-hoc, country by country, approach to decision-making, it will not be mandated that all ActionAid Affiliates must pursue USG funding, but those who do will be provided with a level of support and guidance to help them at a minimum understand the business development and compliance requirements.”

The review also recommended “A further investigation into the costs associated with this option will need to be undertaken in order to establish specific investments needed and a realistic expected return on investment. It is recommended that a small number of country Affiliates are selected and supported in order to bring their organisational systems, policies and procedures to a level which will allow them to be attractive recipients of USG funding.”


The purpose of this consultancy is to help ActionAid International become ready to provide the right sort of compliance support to countries that wish to apply for USAID funding as primes if the Federation decides to start mobilising USAID funding.

This includes but is not limited to:

- Review and analysis of how far the AA Federation does or doesn’t currently meet the requirements of USAID contracting compliance with associated RAG rating

- Reviewing AAI’s policies and identifying areas of tension with USAID policies;

- Reviewing AA’s organisational structure and compliance management approach, and its implications for USAID funding;

- Setting out concrete steps that would need to be taken e.g. specific registrations; training/capacity building, control systems etc. to meet compliance and management requirements

- Identifying potential points of conflict or areas of inconsistency between ActionAid Internationals policies and USAID policies and/or requirements” and suggesting mitigating actions/interventions

- Suggesting potential entry points for USAID funding i.e. most relevant funding streams

- Highlight political trends in USAID funding or administration and ways of following/influencing the political economy of USAID funding

- Sharing experience from other organisations

- Transferring the knowledge to AA countries and IPFT

- Clearly outlining consequences of non-compliance to relevant clauses and severity of penalties


- 20 days to review, interview and write a report


- A report in word or .pdf format and summarised version in PowerPoint, detailing USAID compliance issues, where ActionAid conflicts or would need to examine its compliance, and making suggestions for change

- The report will identify which of ActionAid’s policies would need to be examined for coherence with USAID funding, including but not limited to Child Protection, Prevention of Sexual Exploitation and Abuse, Cross-Border Fundraising, Anti-Bribery and Corruption, and others to be discussed

- Also detailing suitable funding streams for ActionAid i.e. ones that don’t conflict with ActionAid’s values and principles

- A two-hour presentation to senior ActionAid personnel (timing tbc)

Process and Methodology

The investigation process will be a combination of desk research, interviews with key external informants, and interviews with key internal AA informants, together with external inputs from compliance specialists, USAID specialists and other informants.

The process will include review of relevant documents and involve relevant ActionAid staff and relevant Heads of Fundraising and management.

The consultant

You will have extensive experience of both USAID and of complex, federated INGOs. You will have a strong background in compliance and in-country implementation and management of the full USAID project cycle. You will be up-to-date on sector changes and priorities in relation to compliance and other key areas (e.g Safeguarding, Anti-terrorism, cost recovery etc).

Ideally you will have done a similar piece of compliance consultancy in the past. You will have a set of contacts in peer INGOs and the development community with whom you can discuss the task. You will be able to present USAID’s history, its current policies and its likely future direction, and synthesise that with ActionAid’s policies and political position. You will be aware of the overall political operating environment in general and of global donor trends.

About the Organization

ActionAid was founded as a charity in 1972, and throughout our history we have innovated and evolved our approach to better address the structural drivers of poverty and injustice. In the 1990s, we adopted a human rights based approach to development, which we continue to apply. In 2003, we established the ActionAid International federation, comprising members in every region of the world, and headquartered in South Africa. Over the next decade, ActionAid will take action to become closer to the people we work with by strengthening their participation in our governance. We will also deepen our engagement with social movements that share our values and vision to address global inequalities worldwide. Building on our existing programming that supports the agency of people living in poverty and exclusion to claim their rights, we will increasingly connect the people, partners and communities with whom we work, with broader people’s organisations and social movements1 engaged in struggles for justice. This recognises the interconnected nature of many of the issues we work on and the need for greater collaboration and solidarity within and among countries to influence structural change.

More information

USAID Compliance Review ToRs.docx

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