I’m very happy that the U.S. Agency for International Development has posted our independent evaluation (PDF) of its “Colombia Transforma” program, which through 2018 has supported $43 million in “rapid response” efforts to implement Colombia’s peace accord. I worked on this evaluation earlier this year; regular visitors to this site know that this work had me in Colombia for the whole month of February.

In general, we found that the program made important progress in empowering civil society and responding rapidly to some immediate post-conflict needs in the departments of Arauca, Norte de Santander, and Putumayo. They worked in areas where neither the Colombian government nor foreign donors had much prior presence, and they worked with many civil-society organizations that, due to prior experience with “Plan Colombia,” were quite distrustful of the United States. The program, though, did bump up against the frustrations of working with a central Colombian government whose “rapid response” capacity has been abysmal: hidebound by bureaucracy, lack of resources, and unclear leadership.

I’m glad that the evaluation preserves our recommendation that the U.S. government rethink its enforcement of “material support” statutes that make it a federal crime even to buy a cup of coffee for a demobilized FARC member, because the FARC remains on the State Department’s list of terrorist groups.

Now that 14,000 ex-FARC members are at large—many in communities where Colombia Transforma seeks to improve rapid response—the likelihood of inadvertently conferring a benefit upon them has increased. This threatens to paralyze some activities in an absence of clarity about the statute’s applicability to low-rank individual ex-combatants.

…[Recommendation:] Raise awareness within the U.S. interagency about the need for common-sense guidelines for interpreting material support provisions so that they are congruent with Colombia’s current context. Trust that USAID and its implementing partners know not to strengthen a group on the Foreign Terrorist Organization (FTO) list. These guidelines should permit low-level engagement with ex-FARC who are (1) not top leaders; (2) not awaiting war crimes trials in the transitional justice system; (3) not facing U.S. indictments or extradition requests; and (4) reasonably determined to have abandoned violence. Keep a database of supported events with FARC presence for reporting and monitoring purposes. Only halt an activity if it violates the four criteria above, or if the database detects a pattern indicating an attempt to take over the space. Continue to support activities with non-FARC citizens around demobilization sites.

View the whole document here on USAID’s “Development Experience Clearinghouse” site (which is a super useful resource in general, lots to read here).