Akim Kibnovskyi, Compliance Officer, Anti-Corruption & CSR Specialist
Non-governmental organisations (NGOs), intergovernmental bodies, and international funds operate within complex and evolving regulatory environments. Areas such as anti-money laundering (AML), counter-terrorism financing (CTF), formal reporting frameworks, sustainability standards, participation in public procurement, data protection, cybersecurity, and whistleblower protection are no longer relevant only to commercial entities – they now apply equally to the third sector.
Promoting transparency, ethical conduct, sound governance, and effective risk management strengthens relationships with stakeholders, including donors, sponsors, partners, agents, and beneficiaries. Moreover, many NGOs are also active in sensitive areas such as human rights, environmental protection, and health, or work directly with children, all of which carry additional legal obligations and ethical responsibilities.
A Compliance Management System (CMS) offers a structured approach for organisations to meet these expectations. It provides a framework for managing compliance risks, fulfilling legal and donor requirements, and identifying potential issues early. More importantly, it helps embed a culture of compliance within the organisation, encouraging employees to understand and follow applicable requirements in their day-to-day work.
For better understanding, it is worth noting that NGOs are often non-profit, meaning their income typically depends on donations and sponsorship. Implementing a CMS enhances an organisation’s transparency and public credibility – a critical factor when engaging with donors, beneficiaries, and regulatory bodies.
Introducing a CMS should begin with a clear understanding of your organisation’s operational context: What is your project’s focus area? Where are the highest risks? Are there specific regulations or standards that apply to your work? The next step is to conduct an internal review of existing policies and procedures to assess whether they align with legal, regulatory, and donor expectations. Based on this review, a strategy can be developed and implemented to address any identified gaps or weaknesses.
For smaller organisations, challenges such as limited resources, perceived bureaucracy, or slower decision-making processes may make implementation seem daunting. However, compliance systems are not one-size-fits-all – they can and should be tailored to your organisation's size, structure, and capabilities. Despite the initial investment, the long-term value of adopting a CMS – regarding trust, operational resilience, and reputation – far outweighs the potential challenges.