Here is a link to an article prepared by PEAR: http://www.pear-now.org/IndependentAdoptionUnderHague.pdf

This is an excerpt:
“Independent adoptions (those where a placement agency is not utilized and the parents themselves arrange an adoption abroad) are expressly permitted under the IAA and Hague regulation Section 96.13. This comes as a surprise to many who assume that this will no longer be permitted under Hague Intercountry Adoption Act and regulations. The relevant regulation states “Prospective adoptive parent(s) acting on own behalf do not require accreditation, approval, or supervision to adopt” in a
convention country. They may adopt without the assistance of a US placement agency if the convention country’s laws and regulations allow it. An international adoption completely lacking agency involvement is not actually possible in any country since all parents wishing to adopt internationally must always obtain an agency approved home study under CIS rules.”