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Should You Stay?

Risk Management in the “New” Afghanistan - Part 1

By: Joe Gleason, Director Global Risk Management, AHT


As Afghanistan enters a new and uncertain era with the Taliban back in charge, I’m reminded of my first trip to the country in February 2002. It’s an understatement to say I was skeptical as the passport control officer at Kabul airport described the process for getting an NGO visa: Leave my passport at the airport (gulp!), take his handwritten note to the Ministry of the Interior, apply for the visa and bring back a letter of authorization. Sensing our apprehension, a UN staff person offered some much-needed perspective: the process might sound crazy, but it works. The next day, sitting in a room where the shelves were full of binders with the names of various international humanitarian NGOs of all shapes and sizes, it occurred to me that while Afghanistan was new territory for some organizations — like those in democracy, rights, and governance — others had been operating there for years, decades even.


With the events of the past few weeks, I feel a bit like I’m watching history in reverse as some NGOs and international development organizations depart the country while other — mostly humanitarian — organizations vow to remain in the country and do what they do best: deliver critical services and support to Afghans. As organizations adjust to this new reality in Afghanistan, it’s essential to re-evaluate risks and adapt mitigation measures to the changing landscape. In this blog post, I’ll focus on risk management considerations for organizations remaining in the country and, in an upcoming post, I’ll touch on the challenges for those departing the country.


For those organizations remaining in Afghanistan, the risks may be familiar, albeit with new twists and turns:


  • Safety, Security & Health of Personnel – In many cases, these risks will look similar to those encountered in Afghanistan prior to the Taliban takeover — especially for those organizations that previously operated in Taliban-controlled territory. Negotiating access to vulnerable populations to ensure safe, secure freedom of movement without harassment or threat of violence for NGO teams will be essential – and is a core part of humanitarian security. But while some of the risks may be similar, the risk environment has changed. As the Taliban moves from insurgent group to de facto governing authority, rivalries between factions and competition with local power brokers may expose NGOs to the risk of being caught up in disputes over authority. Operationally, much of the infrastructure that organizations have relied upon in recent years have disappeared or shrunk. In particular, there are few(er) medical facilities to address serious illnesses or injuries, making responding to the old nemesis of NGOs — the road traffic crash — a more complicated endeavor. Responding to serious incidents is further complicated by a reduction in flights within as well as to/from the country, limiting the ability to move personnel to safer locations or to higher levels of medical care.


  • Sanctions & Legal Compliance – With a Minister of Interior who hails from a known terrorist organization and other sanctioned individuals in leadership, the Taliban government will likely face a range of sanctions and other measures by the international community. As recent OFAC general licenses for Afghanistan illustrate, governments may work to craft sanctions in order to enable humanitarian or other NGO activities. The details of sanctions are important, so keeping track of developments and adjusting compliance measures on the ground will be critical.


  • Financial – In the immediate aftermath of the Taliban takeover banks closed and organizations scrambled to pay bills. While the situation has eased somewhat, the ability to access funds will be tied in part to sanctions and other global financial restrictions. NGOs on the ground will need to keep aware of the ability to access funds and plan accordingly. Operating with large sums of cash invariably increases the risk of theft and other financial crimes.


Of course, risks don’t exist in a vacuum, and some are interwoven: Kidnapping, detention, and extortion can expose personnel to direct harm but may also raise sanctions concerns if those applying “coercive bargaining” are designated or otherwise sanctioned groups.


Those operating in Afghanistan will need to maintain a high degree of awareness of the risk environment and adjust plans and posture as needed:


  • ASSESS risks and monitor events closely to understand changes in the environment and how they may impact personnel or the organization. As the risk environment continues to evolve this will be a crucial piece — both at the local, operational level as well as at the more global, legal, and compliance level. As many have noted, the Taliban of 2021 is not the Taliban of 2001 (or even 2011) so assessing risks and the key actors is crucial.


  • ADJUST & ADAPT plans and procedures to reflect the evolving risks. Most organizations operating in Afghanistan will have substantial experience in the country, including during prior Taliban rule, so few will have to develop policies and procedures from the ground. Instead, organizations will need to adapt existing systems to meet the current — and evolving — risks.


  • UNDERSTAND how key resources such as medical and security assistance and insurance will work in the “new” Afghanistan. Assistance providers may have limited resources, at least initially as they rebuild networks and facilities are re-established. Insurance may be impacted by sanctions. Flights will be limited, impacting routine movement of personnel, as well as emergency relocation or evacuation (medical and security).


Despite the obvious similarities, Afghanistan in this new era is different from the pre-2001 Taliban-run country. Most notably, a generation of women and girls have come to expect access to education, healthcare, and employment. NGOs operating on the ground will have an opportunity to hold the Taliban accountable for upholding humanitarian commitments and human rights principles.


With Afghanistan teetering on the brink of a “humanitarian catastrophe”, according to the UN Secretary General, NGOs will play a vital role in providing essential services to millions of Afghans. The evolving realities of the new Afghanistan will require careful assessment — and reassessment — of risks and continued adaptation of mitigation measures and resources to enable program activities.

2021 NGO/International Aid Benchmarking Report

This report is a comprehensive compilation and analysis of your peer data to help your senior leadership determine the direction and scale when designing risk management and insurance programs.