Hon Isaac Adongo writes: “Unipass Icums Is A Messed Manual System; Stop The Huge Revenue Theft And Restore Wes Blue/Gcnet Now”

• The Government of Ghana led by H.E Nana Addo-Dankwa Akufo Addo has deliberately deployed a weak so-called Integrated Customs Management System (ICUM) through Unipass to enable he and his cohorts of family and friends steal our dwindling revenues from the Country’s ports.
• For decades, Ghana has been at the forefront of leading innovations in trade facilitations in the sub region. Those innovations came after series of dialogue, research, feasibility studies and surveys that identified lapses in the system and sought credible mechanisms to reverse their impact on trade flows and the bottlenecks to revenue generation. The successful deployment of these initiatives have not only helped to minimise inefficiencies and improved revenue generations in Ghana’s twin ports, they have enhanced Ghana’s image as a destination of choice for traders in West Africa.
• Combined with other initiatives by other stakeholders in the sector, these measures have ensured that trade flows into and through the ports have enjoyed strong growth (until recently), resulting in more revenues generated for the state. In the business sense, these initiatives have also helped to position Ghana’s economy in an attractive light as positive scores in trade facilitation brightens a country’s chances of clinching a better spot in the World Bank’s enviable table of Ease of Doing Business.
• The institutions at the forefront of these achievements have been the Ghana Community Services Network (GCNET), which started operations in 2002, and the West Blue Consulting Ltd, which started operations in 2015.
• Since assuming office, the President and his family and friends have sought to pursue policies to deny the Ghanaian tax payer and the economy the benefits of increased streams of revenue by deploying his costs but ineffective solutions that only tend to benefit his corrupt nature.
• You will recall the termination of the international call clearing house arrangement with Afriwave that saved Ghana millions of dollars in revenues that would have been lost to the state and replaced by the signing of a multi-billion dollar (about $1.2 billion contract) with Kelni-GVG which has proven to have no capacity to independently assure us of tax revenues from the Telcos and the signing of a dubious mobile money interoperability agreement costing the Ghanaian user some (US$1.3 billion) and the infamous Unipass deal that requires Ghanaians to pay more for a useless manual system.

• IMPACT ON REVENUES
• In 2015, the solutions of the two firms, Wes Blue and GCnet were combined to provide an integrated end-to-end processing platform to deliver the Ghana National Single Window (GNSW), the Ghana Customs Management System (GCMS) and its Trade Facilitation Single Window Platform (TFP) -components to meet ISO 9000 and 27000 certification standards. The integration proved successful, resulting in government revenues consistently rising (except in 2019 when government reduced benchmark values at the ports) to the admiration of all governments.
• The data shows that customs revenue generated through the system rose from GHC7.5 billion in 2015 to about GHC13.2 billion in 2018. This represented an accumulated growth in customs revenues between 2015 and 2018 of about 76%.
• Unsurprisingly, the system the two companies have put together has not had any system breaches since its inception. Indeed, the system’s robustness in the midst of expanded port operations has been remarkable as evidenced through the increased revenues delivered year-in-year-out.
• In spite of these outstanding performances, GCNET and West Blue whose contracts are due to expire at the end of 2023 and 2020, respectively, are paid a combined fee of 0.54% of Free on Board (FOB) i.e. taking into consideration government’s 35% shares in GCNET.
• Now, after these years of sustained innovations, deliberate investments and visible improvements in the gains, the country is readying itself to throw away its best trade facilitation service providers for a company that neither has a track record nor a concrete, a defined, a professed or a self-procured system to work with. The Akufo-Addo-Bawumia government is ready to abandon the tried and tested system that the GCNet and the West Blue built for the country for something neither the government nor its promoters have been able to say makes it worth the consideration, talk less of being superior to what we already have in place. They have set in motion a clandestine move to abandon the best for the worst and turnaround and give the best’s platform to the worst to transact business.
• After cancelling the contracts of Wes Blue and GCNET before they fully run out their terms, Nana Addo has taken a dangerous step to saddle this country with potential judgement debts just to satisfy his parochial corrupt interest. What is worse is that the system being implemented at the ports today takes Ghana back to pre-2002 outmoded ancient manual operations at our ports.
• It is instructive to note that this development is deliberate and meant solely to allow Nana Addo and his family and friends weaken the robust end-to-end system that was built by Wes Blue and GCNET to facilitate easy, faster and controlled clearance of goods at the port so they can clear goods for free at the expense of the state.
• For example, the following deliberate approach are being used to steal revenue at the port using the dubious Unipass system;

• WHERE IS GHANA LINK/UNIPASS’S SYSTEM?
• Quite clearly, the ICUMS by Unipass is a scam and a means to re-introduce a manual system to loot national revenue from the port for Nana Addo’s pension and those of his aging family and friends.
• What is incredulous but speaks to the diabolism associated with the government’s decision to sacrifice the best for the worst is that neither the government nor the Ghana Link/UNIPASS have been able to show Ghanaians the system that they are coming to use to execute the questionable contract that the government sole-sourced to them. 
• The GCNET/West Blue system has been audited by both local and international agencies and has been acclaimed globally for its robustness and efficiency. The system has received some of the highest ISO certification for this as well as several local and international awards. West Blue for instance has won some of the most recognised national and international awards, including the World Customs Organisation’s International Best Practice Award, the National Information Technology Development e-Governance Award 2015, the Anas Aremeyaw Anas Transparency Award at the 2017 Ghana Shippers Awards and the Best Technology and Innovative Award at the 2017 Ghana Maritime and Shippers Award.

• In the case of the Ghana Link/UNIPASS, they have no proper track record in the business and no verifiable superior systems that they are ready to deploy in Ghana or that they have deployed elsewhere. And that is a challenge I am throwing to both the government and the Ghana Link/UNIPASS cohorts to show to Ghanaians their system, where and how it was deployed and the track record in superiority. While at it, let me state that the closest anyone can affiliate Ghana Link to port services delivery is through its subsidiary, Africa Link Inspections Company Ltd (ALIC) in Sierra Leone. Information available indicate that ALIC was contracted by Sierra Leone to deliver an end-to-end system in 2012. However, as at January, 2020 when their contract was being terminated, they were yet to deliver a single project. The Company was found not only to have failed to implement important and vital components of their contract, but also to have in connivance with their parent company, Ghana Link, allegedly, manipulated financial records for tax evasion purposes. Again, the Sierra Leonean Authorities also found that ALIC had allegedly failed to pay taxes to the tune of Le45 billion. As a result, the government initiated steps for the abrogation of their contract with the company. Yet, this is the company thr Akufo-Addo-Bawumia government has sole-sourced our trade facilitation project to. But that is not even all.
• In Ghana also, Ghana Link’s earlier scanning and valuation service was noted to be poor.  I, therefore, dare the government and Ghana Link/UNIPASS to provide evidence of their activities that make them a better service provider and a better option to the existing robust end-to-end system that Ghana currently runs with GCNET and Wes Blue Consulting.
• The confusion that ensued at the ports when the government decided to push out the tried and tested GCNet/West Blue Consulting system and bring in Ghana Link/UNIPASS who have no system, to start with, speaks volumes. There is no gainsaying that that confusion will only swell and blossom into huge losses in government revenues at the ports in the unlikely event that the government carries through with its dubious plan.

• THE HIDDEN AGENDA
• In spite of these negative factors, our government led by President Akufo-Addo has decided to replace companies that have been delivering improved services and revenues; companies that are acclaimed globally for their capacity and transparency (as shown by the awards mentioned earlier), with a company that has been found not only to be incompetent and incapable of delivering a Single Window system, but also allegedly, very corrupt.
• I am aware that Dr Bawumia was launching some digital platform yesterday. It so sad that the lame duck Vice President has run away from his so-called paperless port project to embark on other such projects that can only last the selfish business interest of Nana. What is the live span of his digitisation project? One more Unipass or Kelni-GVG interest from Akufo Addo and his family people and we are back to a manual systems
• I wish to inform Hon. Alan Kyeremantan that I respect him so much and would advise him to stay away from attempting to clean up the mess of Hon Osafo Marfo. If he refuses and allows himself to be destroyed, the people of Ghana will combine him and Osafo Marfo for posterity to deal with them.
• The emergence of manual releases and clearing of cargo, manual warehousing of cargo, manual releases of export or transhipment cargo and engendering human interference in the clearing system is a deliberate attempt to abuse the port system and enrich private pockets at the expense of the state.
• The only reason this can happen is when there are ulterior motives. Some of these are;

• Contract Fees
• Why will any government replace a cheaper system that is delivering its mandate with a more expensive one that is unproven to be superior?
• As noted earlier, the combined fees paid to GCNET and West Blue for their services is 0.54% of FOB. With this Ghana Link/UNIPASS deal, government of Ghana has decided, for whatever reason, to pay 0.75% of FOB.
• This was after granting Ghana Link duty- and tax-free importation of their inputs (which GCNET and West Blue do not enjoy).
• Who is ripping Ghanaian importers of the 0.21% FOB? Why will any responsible Government not motivated by greed and corruption charge its citizens more for poor and untested system that simple due diligence in Sierra Leon shows is unworkable?

• The question to President Akufo-Addo is; what specific addition is Ghana Link/UNIPASS bringing on to warrant the extra 0.21% of FOB? Why is government providing Ghana Link with inordinately higher fees for a service that is being provided at a lower cost? Ghanaians want to know why they will be paying more for this unproven system. This is why I cannot resist the termination to state that this project is beginning to lend itself to somebody’s pension project where everything must be done to ensure that it is successfully through to deliver the needed kickbacks for that person when the NPP exits power in January 2021.
• But that is nation wrecking. It is sacrificing a collective and national good for an individual’s selfish and heartless gains. That is why the continuous push of this project makes it obvious that the Akufo-Addo-Bawumia government is recklessly trying to erode the gains that successive governments have made in trade facilitation in Ghana. This GCNET/Wes Blue concept is one of the only projects that each government in the Forth Republic has built upon. The Akufo-Addo government will be the only one to depart from this. And strangely, they are doing so, so recklessly that the potential of saddling the country with substantial judgment debt couldn’t be higher. My believe is that the puppet masters pulling the strings for this transaction could only be motivated by what they stand to gain privately. Those people must be reminded that dawn is on the horizon and they will answer.
• I wish to call on all well-meaning Ghanaians to resist this heinous fraud being visited on Ghanaian importers and business community by Nana Addo and Osafo Marfo and call on the President to cancel the Unipass deal and allow the sanctity of contracts to prevail by restoring and allowing Wes Blue/GCNET contracts to run their unexpired terms.

Hon Isaac Adongo

From the days of the Single Document (SAD) through the Automated System for Customs Data (ASYCUDA), Ghana has never hidden or let go the appetite to digitize the eco-system of its supply chain, pursuing the most efficient path for its international trade and optimizing revenue mobilization whilst ensuring trade facilitation is not encumbered in any way.

Ghana, in 2002 joined the League of Nations that have braced the odds to properly automate their customs processes by employing the services of Ghana Community Networks (GCNET) to set us on this course. This journey we have since progressively updated and extended in line with international best practices.

In 2015, the Government of Ghana phased out the Destination Inspection Companies whose services had been engaged since the year 2000 to replace the pre-shipment inspection system which involved the inspection of imports before shipment from the country of supply.

Customs thus took over their core mandate of Classification, Valuation and Risk Management with Westblue Consulting as the Consulting and Technical Partner for the Division; this ushered in the second phase of the development of the Ghana National Single Window.

BACKGROUND

In 2017, the Vice President of the Republic of Ghana made an audacious move to intervene in the port processes with what he termed the Paperless Port Processes.  This was in apparent response to our clarion call for a Governance Structure that had been missing in the effort at digitizing our clearance process. This was to cure the turf wars and bridge the gaps between the ICT network operators and also amongst the State Regulatory Agencies.

His Excellency, the Vice President succeeded to a very large extent in curing the turf wars and bridging most of the gaps through a 3-pronged policy initiative (the removal of Customs barriers within the country; Mandatory joint inspections and a Paperless Port)

A high point in this arrangement was the removal of Customs Compliance as a

Seat in all Collections at the seaports and get them embedded with the Customs Technical Services Bureau (CTSB) except that there was a slight variation during implementation.

UNIPASS

The argument has been that in the absence of a single vendor a Single Window environment cannot be achieved. So irrespective of the huge gains made by the Paperless Port Policy initiative by His Excellency the Vice President (which has effectively been thrown away with the introduction of UNIPASS), which saw the bridging of the gaps amongst the regulatory agencies culminating in the 3 member inspection team (CUSTOMS, FDA AND GSA) and also the seamless integration between the ICT network operators, the UNIPASS deal came to pass.

An earlier attempt at launching this New Customs clearance system on the 1st of January 2019, was aborted upon a directive from the Economic Management Team (EMT) which came up with a DECISION NOTE dated 20th December, 2018 which in part asked for

a demonstration of a fully developed end to end technology Solution system, successfully tested, with the independent Stress Report
Provide a comprehensive implementation plan to the EMT by end January 2019

On the 25th of February, 2020 we had an invite from the EMT to a meeting and on the Agenda was “Update on the Transition of the Port System: UNIPASS of  Korea Customs, GcNET, West Blue in response to the EMT Decision Note of December 20, 2018”. Also invited to this meeting were GcNet, West Blue, GPHA, Ghana Revenue Authority(Customs), and Freight forwarders. This meeting was called off at the last minute. This means we never got to explore the demands of the Decision Note.

On the 26th of February 2020, we received a letter in copy from the Senior Minister Hon. Yaw Osafo-Maafo, announcing the deployment of the New Customs Management System in 49 designated land frontiers from the 1st of March 2020, chief among which were Paga, Elubo and Aflao.

The Takoradi deployment was officially rolled out on the 1st of April, 2020 and by the 27th day of April when I (President of the Association) visited Takoradi upon numerous complaints, the following (report attached) was observed and appropriately reported to the Honourable Minister of Trade.

It should be noted that it is this report and other interventions that caused a shift in the deployment date of the new system in Tema and KIA from 28th April to 15th May and subsequently to the 1st of June, 2020.

On Monday the 1st of June, 2020 the system was finally deployed in Tema and KIA after a supposed simulation exercise the previous weekend.

ISSUES

Having deployed on the land frontiers it must be noted however that before 1st of June there was laxity of choice between the usage of the existing platform and the New System. Declarants who attempted usage of the new system quickly reverted to the old system due to the challenges encountered.

On the 1st June however, because of the National mandatory rollout, there was no other choice than to contend with the Integrated Customs Management System (ICUMS) as it has come to be known.

Big systems deployment of this sort or even those of lesser magnitude, are bound to suffer initial hiccups or what is universally accepted as ‘teething problems’. ICUMS has effectively deployed for well over 3 months on the land frontiers and over 60 days on the seafront. Seeing that Takoradi mirrors a perfect image of Tema and considering the fact that Takoradi issues had been on the front burner all this while, one really wonders what the objective of the “SIMULATION” exercise was all about when Takoradi had presented an accurate basis for piloting and troubleshooting.

Post 1st June Deployment

On the 1st of June 2020, ICUMS was effectively deployed, GcNet and West Blue were shut down. We were given the marching orders and the directives for what was to become the deployment of a superior system, operated by a single vendor and with an end-to-end seamless delivery. What happened?

1.    INACCESSIBLE SYSTEM

For a few hours after deployment the system was generally inaccessible (screenshots available)

Remarks: This situation was remedied on Day 1

2.    IMPORTER TAX IDENTIFICATION NUMBER (TIN) CHALLENGES

Information about the importer at the entry of his or her TIN should automatically populate for a continual process of clearance. This is the basis for which one begins a declaration but unfortunately, it has been fraught with challenges to this day.

Remarks: Though solutions have been attempted, this has become a recurring challenge of the ICUMS since its inception (Refer No. 16 of Takoradi report attached) leading to a manual solution of importer TIN recapture. It must be noted that this cannot be a solution for a digitized system.

3.    NO BENCHMARK FOR DELIVERY TIME

ICUMS per the ‘Trade Facilitation Agreement with Ghana Link’ has no SLA (Service Level Agreement) indicating process delivery times with which every other stakeholder can plan. Thus declarations can get locked up in the system for weeks with no benchmark for redress.

Remarks: Solutions have generally been on a  ‘piecemeal’  approach. Declarants have had to approach the technical teams at the command center for solutions.

4.    RESORT TO MANUAL PROCESSING

ICUMS as we speak has not been fully integrated with other players in the chain ie. Terminals, Shipping Lines, Ground Handlers and some Courier stations. This has led to the re-emergence of manual processes of release to our chagrin.

5.    SECURITY

Consolidators (Break Bulk)

The back-end operations of one consolidator expose the transactions of other consolidators in form and substance. Consolidator ‘A’, when he or she logs in is able to see the operations of other consolidators in real-time.

Remarks: This is an anomaly because releases can intentionally or unintentionally done for whatever effect. For a superior system of this sort, confidentiality is key to trust.

Absence of Administrators Control

There are no administrative controls. The systems log-in architecture stops the administrator from having any oversight controls once a log-in credential has been created for the Assigns. (Refer No.12 of Takoradi report attached)

Remarks: This is a serious anomaly. The administrator must necessarily be able to view and effect audits of every single declaration done.

6.    SYSTEM CALCULATOR CHALLENGES

There seems to be a huge problem with the computation of figures in ICUMS, and of particular interest is that of vehicle declarations. We also have noticed a trend of Customs Validated Duty Declaration Documents with figures which defy reason. Below are a few examples:

●      Wrong application of Exchange Rate.

Forex conversion for duty purposes requires a simple multiplication of the exchange rate by the figure in question. The product of this calculation should never be in dispute, but we have situations of botched calculations. Evidence abounds.

●      Non-application of required Taxes

In several instances, the one percent inspection fee (which is subject for discussion) has not been charged. This is not to say it is not being charged at all because in other cases this fee has been charged.  Certainty must be brought to bear.

●      Wrong application of Taxes

Taxes (1% Inspection Fees) have been erroneously applied together with Vehicle Examination Fee in vehicle duty computation.

●      Bizarre computation of Taxes

We have seen bizarre situations of declarations with tax bills which double at the time of payment at the banks only to be told that these are system errors. Also in this bizarre category is a declaration with a mysteriously increased tax base and a corresponding hike in IRS fee with no relation to the declared or assessed CIF (cost+insurance+freight).

7.    CALL CENTRE

We have forever indicated that at the epicentre of this whole ecosystem is the presence of a top-notch Call Centre. (Refer no. 25 of Takoradi report attached).

It is evident that this has not materialized. The constant trooping of our members to the command center in search of solutions betrays the non-responsiveness of a functional call center as we must have it.

8.    INFORMATION MANAGEMENT

The flurry of letters (some of which immediately come to cancel earlier ones), process instruction diagrams, instructions just popping up on our social media platforms does not suggest a coherent project delivery. This is raising a lot of anxiety and a nightmare for change management in the whole chain.

9.    TRAINING

Training (Refer no. 24 of Takoradi report attached) has been poorly managed leading to fatigue amongst declarants. Follow up training sessions are popping up only a week after full deployment which only underscores our earlier observation of a not-so-well packaged delivery.

10.  FRONTIERS

For the first 4 days of June, no import declaration had gone through at most of the frontier stations. For now a lot of manual interventions have been resorted  to.

There are reports of ICUMS inability to issue the Temporary Vehicle Importation (TVI) certificate.

We have had reports of sudden restrictions on some Customs Procedure Codes even though the Schedules remain unchanged. The effect of this is the application of statutory levies whereas in recent past those levies were not applicable.

The introduction of Manifest creation and Bill of Lading at the road frontiers comes as a strange requirement and this is having a toll on the operations of declarants.

We have had to contend with so many issues with this change; cost is escalating because all time related fees (Demurrage, Terminal rent, State Warehouse Rent, Ground Handlers Rent at the Airport, Truck Demurrage at land frontiers), have not been held in check as we contend with massive delays and as a result of the change in processes.

If this is the new normal, the scope of the whole delivery chain will have to be redefined. Not too long ago, when PAARS was deployed it reduced the delivery time of CCVRs to a publicized 48 hours as per their Service Level Agreement (SLA). The ground handlers at the Airport took a cue and slashed down the free allowable days from 8 to 4 days.

This request to redefine the scope should be treated with all seriousness. Operators within the chain must not benefit undeservedly from a situation which has arisen through no fault of the Trader.

The government will have to carefully appraise this dire situation and advise itself on the choices to make going forward in this matter.

By EDWARD AKRONG, PRESIDENT – GHANA INSTITUTE OF FREIGHT FORWARDERS (GIFF). 08/06/2020