TCA - Ghana DRM Report (Condensed).pdf

This document is made possible by the support of the American people through the United States Agency for International Development (USAID).

It was produced for the USAID Trade and Competitiveness Activity in collaboration with the Bureau for Economic Growth, Education and Environment (E3) Office of Trade and Regulatory Reform (TRR). Its contents are the sole responsibility of the authors and do not necessarily reflect the views of USAID or the U.S. government.

GHANA DOMESTIC REVENUE MOBILIZATION

(DRM) ACTIVITY

ON CUSTOMS MANAGEMENT

September 2019 – Summary Report

1 | GHANA DOMESTIC REVENUE MOBILIZATION (DRM) ACTIVITY ON CUSTOMS MANAGEMENT

The USAID Mission in Ghana requested assistance to determine the best way to support the Ghana Revenue Authority (GRA) and particularly the GRA Customs Division (GRA – Customs) as part of a larger project plan on improving DRM in Ghana. In response, USAID’s Trade and Competitiveness Activity formed a multi-agency team to conduct an assessment of Ghana’s customs operations. Overall, the team found that the same inspection controls are being applied to all incoming cargo multiple times. The result is that businesses have little incentive to become compliant. GRA – Customs should implement risk-based customs controls that reward compliant businesses through fewer examinations and/or less stringent controls, and concentrate on inspecting high-risk shipments from known non-compliant traders or businesses without compliance history. These procedures are essential for enhancing the effectiveness and efficiency of Customs in revenue collection. They also attract foreign traders and investors that value transparency and predictability to move their shipments quickly, efficiently, and at a reasonable cost.

GHANA’S CURRENT RISK MANAGEMENT PRACTICES

GRA – Customs’ risk management practices are not currently in alignment with the specifications of the World Customs Organization (WCO) and the requirements of Article 7.4 of the World Trade Organization Trade Facilitation Agreement (WTO TFA). The Government of Ghana has taken some steps to streamline customs procedures. As of July 1, 2019, the Government of Ghana has mandated that Customs reduce Red Channel examinations to 10 percent of shipments and Yellow Channel to 30 percent, while expanding Green Channel to 60 percent (no document review or examination). GRA – Customs also signed a Memorandum of Understanding (MOU) with Korea Customs that will replace PAARS and GCMS with the UNI-PASS e-customs system and provide associated trainings. UNI-PASS has a well-respected risk management component that should help resolve problems associated with PAARS and GCMS. GRA – Customs should still receive training on the UNI-PASS system and compliance-based risk management in order to meet WCO and WTO standards.

Informal Risk Management

During interviews with Customs Officers, it was clear that while there was good awareness of potential risks, there could be better documentation. The informal risk knowledge and experience of Customs Officers must be captured in the automated systems, both at the pre-arrival and arrival points. This information will become the historical data that will inform future risk assessments and will be critical to a fully functional risk module in UNI-PASS.

DRM Impact: Formalizing the capture and analysis of historical data to address risks can improve detection of non-compliance, reduce non-compliance, and thereby generate Customs revenue.

Recommendations:

● Reorganize Customs RM functions inside a dedicated Unit within the GRA Customs Division that reports to the GRA Commissioner General, with strong linkages to Intelligence and Investigations

● Develop clear RM framework, policy, and strategy

● Form a focus group of officers with a higher-than-average success rate in detecting non-compliance and revenue leakage, and integrate their inputs on risk factors within the UNI-PASS RM module

● Conduct basic RM training for officers and other stakeholders from Intelligence and Investigations Account Management Program

GRA – Customs does not currently have an Account Management Program that adequately uses account-based methods, rather than transaction-based ones, to enforce, regulate, and administer trade laws. (An account is an importer or a customs broker.) By viewing a company and its trade performance in the aggregate, account management should raise compliance, facilitate the flow of legitimate trade, and

2 | GHANA DOMESTIC REVENUE MOBILIZATION (DRM) ACTIVITY ON CUSTOMS MANAGEMENT

increase efficiencies. It does so, in part, by providing an Account Manager (AM) to significant importers, Primary Focus Industries (PFIs), and broker accounts. The AM is the primary point of contact within Customs to establish smooth working relationships with accounts and handle trade-related issues.

DRM Impact: Creating an Account Management Program will enable Ghana to analyze trade performance on the company level rather than on the transaction level. This will allow GRA – Customs to more accurately classify shipments according to risk, which will in turn generate revenue by reducing revenue leakage and lowering the time and resources spent on Customs procedures.

Recommendations:

● Establish Account Manager position descriptions with Human Resources Management (HRM) for both

AM and Assistant Commissioner (AC) levels

● Recruit Account Managers from existing Customs staff to be dedicated to Ghana’s PFIs

● Assign Account Managers to Ports of Tema and Takoradi

● Allocate commodity specialists from existing Headquarters officers to primary ports

● Assign National Account Managers to oversee the program Authorized Economic Operator (AEO) Program

GRA – Customs is designing an Authorized Economic Operator (AEO) program, scheduled for implementation in September 2019. AEO is a smart control strategy that provides customs benefits to trusted traders known as Authorized Economic Operators, including faster clearance and reduced or priority Customs examinations. AEO puts the onus on the importer to enter, classify, and value its goods to enable Customs to properly assess duties, collect statistics, and ensure legal requirements are met. In Ghana, importers are required to employ customs brokers to prepare and file entry.

DRM Impact: By facilitating a strategic alliance with exporters/importers through AEOs, GRA – Customs can free up resources that address non-compliance and companies that present a greater risk. This can reduce trade inefficiencies and increase the volume of trade thereby benefiting DRM overall.

Recommendations:

● Identify the top risk indicators for AEOs based on data analysis

● Receive training on AEO compliance

● Include account management in Ghana’s AEO Program Transit

Port officials believe that a significant number of in-transit containers never leave the country or arrive as designated by procedure code at warehouses and Free Zones. Similarly, sometimes trucks arrive at the border for export but the merchandise is not recorded as being in the container. These events could be due to the lack of procedures to reconcile in-transit records, verify merchandise, and track shipments, or the result of a Customs Officer falsifying a record. The UNI-PASS system should provide the automated tracking necessary to address several of the control issues, while two other projects are being undertaken by GRA to enhance in-transit tracking.

DRM Impact: Improving transit tracking at GRA – Customs, especially through automated systems, should greatly reduce revenue leakage by increasing the number of in-transit containers that arrive at ports, warehouses, and Free Zones.

Recommendations:

● Provide technical assistance to ensure transit tracking systems are used to the fullest extent to reconcile in-transit records and improve Customs procedures

● Request WCO assistance for a Time Release Study (TRS) to identify choke points that cause delays, raise the opportunity for corruption, and increase cost and uncertainties of shipment clearance

3 | GHANA DOMESTIC REVENUE MOBILIZATION (DRM) ACTIVITY ON CUSTOMS MANAGEMENT

● Fully involve Internal Affairs to address corruption concerns

● Utilize Post-Clearance Audits for high-risk declarations Vehicle Importation

Vehicles are a major source of import revenue for Ghana, accounting for nearly 10 percent of the value of all imports and approximately 25 percent of all Customs collections. While Ghana places high duty rates on many vehicles, it does not follow WTO GATT guidelines to determine value. By instead using the Manufacturer’s Suggested Retail Price (MSRP), vehicles in poor condition are taxed just like those in excellent condition. The high rates of duty and method of valuation can lead to increased smuggling of vehicles in containers and through porous borders. Moreover, there is significant redundancy in processing of vehicles. Our team also found that port officers do not have adequate training to determine the type of vehicle for classification (engine size, hybrid, etc.), which affects the rate of duty.

DRM Impact: If GRA – Customs changes its valuation procedures to meet WTO GATT standards, the country may reduce smuggling and potentially raise revenues. If GRA – Customs eliminates redundancies, it can free up resources to be better utilized in other areas to improve Customs compliance and DRM.

Recommendations:

● Follow WTO GATT valuation procedures

● Streamline redundant processes Customs Brokers

In Ghana, customs brokers are not held responsible for non-compliance, except in grave instances where their license is suspended or revoked. Penalties, if any, are assessed on the importer. A broker warning and penalty regime that allows for escalating penalties on a case-by-case basis provides for consistency and transparency. For this to be effective, Customs needs a centralized Intelligence database to record all the relevant details of offenses for future reference.

DRM Impact: Sanctions applied to non-compliant brokers will reduce broker fraud and increase collections. Partnership with ethical and compliant customs brokers can also increase DRM.

Recommendations:

● Adopt a simple escalating penalty plan Embedded Advisor

During the team’s close-out briefing with the CG, the group specifically discussed the possibility of placing an embedded advisor in GRA to follow through on recommendations and serve as a mentor and coach to Customs staff. It can be costly in terms of both expense and time to find the “right” embedded advisor.

Before hiring and supporting an embedded advisor, GRA would need to receive HRM support, including the creation of position descriptions for Risk Analysts or Officers assigned to the Customs RM Unit.

DRM Impact: Unknown at this time.

Recommendations:

● Initially, conduct frequent technical assistance missions to implement recommendations, which may more effectively achieve the same benefits as an embedded advisor

● Deliver technical assistance in basic RM training, Training of Trainers in RM, and HRM prior to considering an embedded advisor Site Visit: Port of Tema

As the largest and busiest port in Ghana, the Port of Tema must be the focus of modernizing Customs processes and eliminating procedural redundancies. Importers are assessed a fee when shipments are scanned, resulting in additional costs and delays. As at Customs HQ, positive results from scanning are

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extremely low. Customs stated that there are no background checks for those who work at or enter the port, which will need to change to implement WCO SAFE standards. Interviews with Customs Managers reveal that although control is an issue at Tema, this concern has been reduced by stationing Customs Preventive Officers at exit gates to confirm clearance and release.

DRM Impact: Customs indicated that they believe there is significant revenue leakage in many areas within and outside Tema Port, as control of warehouse movements, Free Zone operations, and in-transit shipments is insufficient. The UNI-PASS system will provide the ability to audit these functions and determine the extent of the leakage. Audits are essential to measure compliance of goods under Customs control and measure where the greatest risks for revenue leakage, safety, and security exist.

Recommendations:

● Begin accepting scan images to be part of the declaration package when UNI-PASS becomes operational; although private operators are currently doing this, it will provide Customs with the ability to audit the work of the private operators

● Audit shipping manifests to ensure bills of lading are properly controlled and released by Customs

● Audit documents that control warehouse movements, such that all movements to and withdrawals from warehouses are properly documented and associated revenue collected

● Audit documents that control movements to Free Zones, such that Free Zones operations meet regulations and goods removed from Free Zones are exported and duties/taxes paid Site Visit: Kotoka International Airport (Cargo) Processing

Imports often remain unclaimed at the warehouses primarily due to lack of communication from brokers to importers that their goods have arrived and been released by Customs. In interviews, Team Member LaShandra Dupree (of U.S. Customs and Border Protection) was told that only 1 percent of the shipments are duty satisfied and claimed. Broker compliance needs to be secured with a reasonable penalty scheme for non-compliance. Importers often abandon shipments with high fees, which creates both a security and infrastructure issue by filling warehouses to capacity. GRA – Customs should hold scheduled auctions of abandoned/unclaimed goods before they lose value.

DRM Impact: Levying penalties on non-compliant brokers will result in fewer abandoned imports and therefore a greater number of duties will be paid on imports. Auctioning abandoned shipments before they decrease in value present another opportunity for GRA – Customs to augment revenue collection.

Recommendations:

● Simplify and streamline the process of notifying importers of the arrival and clearance of shipments,

● Penalize non-compliant brokers that fail to notify importers of shipment arrival and release

● Conduct quarterly speedy auctions for unclaimed/abandoned goods to save space for incoming goods; consider an additional state warehouse to be used for auctions only

● Schedule shipments abandoned/unclaimed for more than 29 days for movement out of the arrival warehouse to the auction warehouse, which will improve security and free up infrastructure

● Enhance the security and organization of shipments in both the arrival and auction warehouses Free Zones

Controlled movement of shipments going in and out of the Free Zones is paramount to revenue mobilization. The raw materials going into the Free Zone must be reconciled with the finished product claimed. Currently, it appears that GRA – Customs is not monitoring the raw materials claimed on the declaration documents as entering the Free Zone and reconciling those raw materials (including a formula for waste) to the declaration documents filed for the claimed finished product upon exiting the Free Zone.

5 | GHANA DOMESTIC REVENUE MOBILIZATION (DRM) ACTIVITY ON CUSTOMS MANAGEMENT

DRM Impact: By more accurately classifying raw materials and finished products, Customs will reduce the risk of revenue leakage created by Harmonized Tariff Schedule (HTS) misclassification.

Recommendations:

● Levy penalties on Zone operators for non-compliance

● Enact clear guidance regarding 1) Zone operators’ responsibility for on-site supervision, inventory, and recordkeeping of Free Zones and 2) Customs’ responsibility for tracking and monitoring the movement of shipments in and out of Free Zones

● Develop Standard Operating Procedures (SOPs) for Customs Officers

● Conduct compliance reviews of Free Zones to determine whether Zone operators are in compliance with applicable laws, provide valid data to establish risk assessment, and assess the reliability of Free Zones’ operating and reporting procedures and internal controls

Customs Laboratory

Lab staff expressed the need and desire for a larger facility, improved technology, and more training. For efficient use of the equipment, lab workers need to have “hands on” access to the equipment. Although most of the equipment is currently in use, there is not much space to properly operate the equipment.

There is also inoperable equipment which can only be serviced by a vendor representative in South Africa.

Customs could benefit from the lab’s specialization in fraudulent invoice analysis, given that one of the largest contributors to revenue leakage is fake invoicing. With the proper technology and training, the lab could detect fake invoices through LED lighting, paper, ink, trace elements, etc. The laboratory could also be better equipped to detect Country of Origin misrepresentation and HTS misclassification.

DRM Impact: By more accurately detecting fraudulent invoicing, Country of Origin misrepresentation, and HTS misclassification through the Customs Laboratory, GRA – Customs will reduce revenue leakage.

Recommendations:

● Purchase lab equipment from vendors with local service representatives in or very close to Ghana

● Use the mobile laboratory at the borders for on-site emergency response and programmatic on-site border security operations

● Determine further recommendations through the Needs Assessment that is currently being administered to lab staff to quantify and qualify the need for a larger space, training, and equipment

CONCLUSION

The GRA Customs Division has an agency-wide need for capacity building in risk management (RM). To mainstream RM as an approach to border management, GRA – Customs should clearly articulate and communicate a risk management policy, strategy, framework, and associated Standard Operating Procedures, and reorganize Customs RM functions within a dedicated RM Unit. GRA – Customs must also embrace the use of data-driven risk analysis to identify high-risk shipments, including by developing cargo risk indicators and selectivity criteria. The shift to UNI-PASS has the potential to eliminate procedural redundancies that disincentivize compliance and hamper DRM, but this transition must be accompanied by significant technical assistance to ensure it will be managed effectively.

The team’s envisioned Action Plan for DRM-focused customs reform in Ghana is attached as an Annex.

Throughout this process, USAID/Ghana can help usher in new solutions to better connect customs reform efforts to Ghana’s DRM priorities. Dynamic risk management, AEO, and trusted trader programs, cost-benefit analysis, and Post-Clearance Audit verification programs are some of the approaches USAID can leverage to strengthen both trade facilitation and DRM. With these tools, Ghana can hopefully sustainably raise domestic resources, enhance economic competitiveness, and accelerate its development journey.

6 | GHANA DOMESTIC REVENUE MOBILIZATION (DRM) ACTIVITY ON CUSTOMS MANAGEMENT

ANNEX – ACTION PLAN/ROADMAP FOR DRM ACTIVITY ON CUSTOMS MANAGEMENT

This roadmap is meant to reflect both actions to be conducted in-house by GRA – Customs as well as opportunities for parallel Technical Assistance (TA) to be provided by USAID or other donor agencies as necessary.

Activity Action to be Completed Timeframe Responsibility Status Remarks Require Maritime Pre-arrival E- Manifest

Approve assessment recommendation requiring the pre-arrival maritime manifest (as currently required for air cargo).

Hold public-private dialogue (PPDs) with maritime carriers and shipping agents regarding the intent to require pre-arrival submission of the e-manifest as the manifest is the primary control document.

Implement the pre-arrival maritime manifest requirement.

Phase 1 – immediate

Immediately following approval

Upon completion of PPDs

Commissioner of Customs (CC), DC Policy and Programs (DC P&P)

DC Operations

(DC O)

PPDs with Public Affairs

Risk Management

Review and approve assessment recommendations for risk management and adopt a strategic plan for implementation.

Establish a transition team to manage the evolution from the current HS-based pre-arrival risk management to an institutionalized holistic approach to risk management, including developing selectivity criteria and data mining.

Capacity building on basic risk management principles according to WCO and WTO for Transition Team (TT) and key stakeholders.

immediate

Phase 1 – Concurrent with approval after selection of transition team

CG, CC, DC P&P,

DC-O

CG, CC

Technical Assistance (TA)

7 | GHANA DOMESTIC REVENUE MOBILIZATION (DRM) ACTIVITY ON CUSTOMS MANAGEMENT

Task transition team to create a national customs RM implementation framework, including regulations and procedures and a consistent methodology to apply RM to import, export, and transit goods.

Develop a formal structure for RM within GRA – Customs with well-defined roles and responsibilities and clear reporting lines.

Review and revise organigram for Customs RM including report structure.

Develop position descriptions for Risk Analysts with Human Resources Unit.

Allocate resources needed to provide suitable staff, facilities, equipment and IT in support of data collection, analysis, evaluation, and dissemination of RM information. Staffing needs should be addressed by the reassignment of existing staff performing redundant functions.

Review and approve assessment recommendations for creation of a Risk Management Steering Committee (RMSC). The Risk Management Steering Committee provides the impetus for change, the direction and support to lead GRA – Customs from the existing traditional cargo clearance process to one of risk management cargo selectivity. The Steering committee has the responsibility to provide the Risk Management Unit, and indeed the entire Customs administration, with a concise statement of its priorities, and responsibilities. In an oversight role, the Steering Committee ensures fully documented risk profiles, conducts productivity reviews, approves criteria modifications or deletions and reports on the effectiveness of risk criteria.

Prepare Terms of Reference for the RMSC including role, functions, responsibilities, and committee members according to function.

Create a RMSC within GRA Customs to provide oversight and direction to the RM units. Include the Steering Committee Charter in the RM strategy.

Phase 1 – Following training

Phase 1 – Building on the implementation framework Phase 1

CG, CC, DC P&P,

DC-O, TT, and TA

TT and TA CC, and HRM

CG, CC, TT, HRM,

and TA if requested

CC, TT, HRM, and TA if requested

CG, CC, HRM,

and TA if requested

CG, CC, TT

CG, CC, TT

8 | GHANA DOMESTIC REVENUE MOBILIZATION (DRM) ACTIVITY ON CUSTOMS MANAGEMENT

Inaugurate the RMSC and Conduct first meeting of the RMSC.

Produce and disseminate a National Risk Management Plan.

Active involvement of top management and senior officers from all affected areas in support of implementing the National Risk Management Plan.

Review feasibility to co-locate the Customs RM Unit with Intelligence and Investigations Unit to facilitate productive communication and share information. This will require Intelligence and Investigations, if organizationally reporting to the CG, to have representation in the RM Unit.

Integrate a reliable and Dynamic Valuation Database to be used as a RM tool into UNI-PASS. (Consider possible TA from WCO).

Phase 1 – Critical following creation of the

RMSC

Phase 2-2.5

CG, CC, Deputy Commissioners TT, possible TA

RMSC and TT with CG and CC approval

CG, CC, DCs, ACs, TA

CG, CC, RMSC,

Intelligence and Investigations DCs

TA from WCO, IT, UNI-PASS, RMSC

Time Release Survey

Conduct a Time Release Survey with technical assistance from WCO in order to identify areas of delays, costs, and uncertainty of doing business.

Through TRS, potential areas of revenue leakage can be identified and addressed.

Phase 1 – High Priority

CG, CC, Deputy Commissioners, and WCO

Capacity Building

Review and approve assessment recommendations for training needs and prioritize.

Capacity building of staff reassigned to the RM functions, managers, Intelligence, and Investigations. This includes defining risk levels, creating risk profiles, developing risk indicators and criteria, and using RM

Phase 1 – High Priority

Phase 1 – After development of the National RM Plan

RMSC, TT, and TA

9 | GHANA DOMESTIC REVENUE MOBILIZATION (DRM) ACTIVITY ON CUSTOMS MANAGEMENT

matrices and risk analysis, including reporting discrepancies/non-compliance.

Deliver capacity building in RM to a cadre of trainers, i.e., a Training of Trainers and integration into the National Customs Training Plan.

Conduct Account Manager Training.

Conduct training on AEO Compliance.

Simplify of cargo clearance procedures, eliminate redundant processes, and create Standard Operating Procedures for each functional area.

Phase 2

Phase 2.5 – Upon internal recruitment and selection

Phases 1-3

CC, HRM, DC

Training and Development, and TA

AC Training, TA

AC Training, TA

CC, HRM, DCs, AC Customs Training and Development and TA

Information Technology

Work with UNI-PASS transition team to establish reliable data migration from GCNet and provide training on how and why to continually update risk profiles.

Expand and utilize intranet to share information on a need-to-know-basis, thereby reducing silos.

Form a focus group of officers with a higher-than-average success rate in detecting non-compliance and revenue leakage, and integrate their inputs on risk factors within the UNI-PASS Risk Management module.

Phase 1 – During migration to UNI-

PASS

CC, IT, CTSB, TT,

IT, and RMSC

AEO Program Review and approve the recommendations of the assessment regarding Authorized Economic Operator (AEO) programs based on compliance risk management.

Phases 1-2

CG, CC, AEO

Coordinator, DANIDA

10 | GHANA DOMESTIC REVENUE MOBILIZATION (DRM) ACTIVITY ON CUSTOMS MANAGEMENT

Identify the top 20 traders by volume and value/revenue received and determine their level of compliance and eligibility for AEOC (Compliance) program.

Conduct outreach to the top traders to generate interest in the program.

Conduct trader- and systems-based (desk) audits and readiness assessments to identify compliance levels and recommend traders suitable for AEOC.

Implement AEOC program.

Continue working with highly compliant traders to further improve compliance with ongoing readiness assessments for more traders to join the program.

Work closely with the Risk Management Unit to continue improving compliance levels and increasing supply chain security and progress towards implementing an AEOS (Security) program.

Work towards mutual recognition with other Countries’ AEO programs.

Possibility to start with U.S. companies operating in Ghana.

Phase 2.5

Phase 3

Coordinator

Change Management

Institute change management for RM throughout GRA Customs. This entails communicating the reasons for and benefits/impacts of change and must include not only Customs Officers and employees but also those in the trading community (importers, exporters, transportation companies, brokers, and others), as well as government counterparts in the other border control agencies as well as trade regulatory agencies.

Undertake awareness workshops/meetings and extensive communication efforts to run concurrent with implementation of the RM system within Customs, MDAs, and traders.

CG, CC,

Managers, government counterparts, brokers and traders. TA if requested

11 | GHANA DOMESTIC REVENUE MOBILIZATION (DRM) ACTIVITY ON CUSTOMS MANAGEMENT

Create a GRA-wide communication plan delivering a consistent and effective message to ensure uniform understanding and common acceptance of RM as a critical trade facilitation and customs modernization methodology.

RMSC, TT, RM

Unit members, Trainers

RMSC, TT, RM

Unit members, Trainers

Human Resource Management

Review and approve assessment recommendation for the creation of Account Managers and National Account Managers.

Create Account Manager positions, both at the major ports and at HQ to service both public and private sectors.

Commence internal recruitment and selection of Account Managers.

CG, CC. RMSC,

TT, HRM, and TA

CC, HRM

12 | GHANA DOMESTIC REVENUE MOBILIZATION (DRM) ACTIVITY ON CUSTOMS MANAGEMENT

Broker Compliance

Review and approve assessment recommendations on broker penalties.

Review existing practices and submit proposals for changes to current broker licensing and penalty requirements.

Implement a broker and trader awareness program regarding warnings and penalties.

Establish service charter between the Customs Services Department and the private sector, including customs brokers, setting out the expectations of each party from the other, as well as the parameters for the expected level and quality of services.

Implement warnings and penalty regime.

Review results for the previous 12 months and conduct post-penalty compliance analysis of brokers and traders that have been warned or sanctioned, taking particular note of whether the Risk Management Unit (RMU) has been informed of the action.

Ongoing application of penalties and compliance testing, adjusting compliance measurement as necessary.

Phase 2.5-3

CG, CC, ACs, TT, RMSC

CG, CC, ACs, TT, RMSC

CG, CC, ACs, TT, RMSC, TA if requested

Post- Clearance Audit (PCA)

Re-orient focus of Customs PCA to serve as an extension of Customs border controls to support risk assumptions on a transaction-by-transaction basis. Conduct associated capacity building.

Develop and deliver specialized PCA training for trader- and systems-based desk audits.

Conduct regular PCA declaration-based compliance audits to identify non-compliance.

CG, CC, PCA Unit, RMU, RMSC

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Review progress of Customs PCA Unit and work closely with the RMU to identify declaration-based risk.

Intelligence Identify the infrastructure and IT requirements to implement and automated intelligence database and management system integrated with the RM module.

Phases 1-2 CG, CC, AC Intel, IT, RMU

Monitoring and Evaluation

Institutionalize a holistic and consistent Customs RM methodology, including: Procedures; Integrated IT Systems, with reliable data and user-friendly report functionality; Consistent application of selectivity criteria based on sound risk indicators; and a Method for communicating, exchanging, and assessing risk- related, local, regional, and national information in GRA, MDAs, and the private sector.

Implement a system of continuous monitoring and evaluation to determine the accuracy of risk selectivity criteria, adjusting as necessary based on: Number of significant discrepancies, based on the criteria and exam instructions; Feedback loop operating; Additional revenue collected;

Notable seizures or prosecution of violators; and Realistic targets for red channel examinations (30 percent), yellow channel (20 percent), blue channel (10 percent), and the default green channel (40 percent).

Establish risk criteria and risk profiles, and conduct data modelling with the MDAs for permanent inclusion in UNI-PASS according to WCO standards and technical assistance.

Continue assisting relevant MDAs in adopting RM practices. Maintain close working relationships and have regular meetings with MDAs involved in the control and clearance of goods.

On-going by all involved departments departments, possible WCO TA

On-going by all