Financial Crime World

US Department of State’s Approach to Risk Assessment and Mitigation

The US Department of State has developed a comprehensive approach to risk assessment and mitigation for its programs. This approach involves performing basic procedures and best practices during the pre-award phase, assessing risks using various methods, and implementing safeguards to mitigate identified risks.

Pre-Award Phase Procedures

Key Requirements

  • All programs must perform screening recipient organizations against sanctions lists.
  • Bureaus within the Department must adhere to the Office of the Procurement Executive’s procedures.
  • The Office of the Legal Adviser must be consulted for guidance on legal matters.

Risk Assessment and Mitigation

Risk Assessment Methods

  • Bureaus use various methods to perform risk assessments, including:
    • Categorizing risks as organizational, programmatic, or country/region-specific
    • Assigning numerical values to each risk factor within each category

Example Methodology

  • The Bureau of Political-Military Affairs’ Office of Weapons Removal and Abatement (PM/WRA) uses a specific methodology that involves:
    • Assigning numerical values to risk factors within each category
    • Tallying the total for each category
    • Designating each category as “High,” “Medium,” or “Low” risk
    • Determining the overall risk profile by weighting the organizational and programmatic categories at 40% each and the country/region-specific category at 20%

Revisiting Risk Assessments

  • The Department’s guidance requires that risk assessments be revisited any time there is a significant change to programming activities, in-country context, or other relevant factors that determine a program’s overall risk level.

Tailored Approach

The US Department of State takes a tailored approach to risk assessment and mitigation for each program, considering various factors and using different methodologies to assess risks. Bureaus within the Department have discretion as to whether they perform vetting, which safeguards are appropriate to mitigate risks, and whether they want to refer certain cases to the RAM (Risk Assessment and Management) vetting program for further evaluation.

Conclusion

The US Department of State’s approach to risk assessment and mitigation is designed to ensure that programs are implemented safely and effectively. By performing thorough risk assessments and implementing safeguards, the Department can mitigate risks and promote the success of its programs.