GHANA DOMESTIC REVENUE MOBILIZATION (DRM) ACTIVITY ON CUSTOMS MANAGEMENT

A multi-agency technical assistance assessment team was formed to review previous assistance provided by donors and build on the findings and recommendations of the Joint Government of Ghana (GoG) – United States (USG) Domestic Revenue Mobilization Needs Analysis Report (JNA Team Report) and the 2018 USAID Risk Management Rapid Assessment. The assessment team met with various public and private sector entities, including the Deputy Minister of Finance, the GRA Commissioner General, and private sector associations such as the Global Alliance, the Ghana Chamber of Commerce and Industry, and American Chamber of Commerce (AmCham). The team also visited the Ports of Tema and Kotoka International Airport cargo operations. Discussions with customs officials at all levels revealed resistance to improving risk management understanding to identify high-risk shipments and allow those designated as low-risk to pass without examination. Effective risk management of goods is a foundational and necessary pillar for trade facilitation in any country. In managing risk, a balance must be established between costs and benefits, as it is clearly not cost-effective to address all risks equally and criteria are needed to determine what constitutes an acceptable or unacceptable level of risk. The application of risk management enhances the effectiveness and efficiency of customs business in collecting revenue and protecting society. The GRA Customs Division had Risk Management in name only, and what was referred to as Risk Management was not in alignment with the specifications of the World Customs Organization (WCO) and the requirements of Article 7.4 of the World Trade Organization (WTO) Trade Facilitation Agreement (TFA). The overlapping processes of pre-arrival and upon-arrival document review apply to every importation, resulting in every declaration undergoing Yellow Channel (document review) control. The Government of Ghana mandated arbitration to resolve disputes related to customs procedures. The assessment team found that the GRA Customs Division had made significant progress in other areas, including the implementation of an INTRANET and Internal Management System, the Joint Government of Ghana – U.S. Government DRM Needs Analysis (JNA), and the IMF Data Matching (Domestic Tax data and Import/Export) project. However, risk management remains the highest priority, and the team recommended that the GRA Customs Division establish compliance-based risk management. The team also noted that the Minister of Finance announced a major "shake-up" in the top-level management of GRA, which may impact the implementation of the recommendations.