Even before Parliament decides on IMANI’s enquiry into the controversial UNI-PASS trade deal, the Economic Management Team, which we had earlier copied in our letters, in a letter dated yesterday, December 20, calls for a suspension of the deal to take off on January 1, 2019 until August 2019, not before a proper economic and legal review has been conducted. See attached letter.

For the purpose of reminders, below are some of the crucial questions IMANI asked.

1. According to the Ministry of Trade and Industry (MoTI), the introduction of UNI-PASS is expected to make the Ghana National Single Window (GNSW) more comprehensive. In addition, the UNI-PASS system will include a clearance management system, a cargo management system, an information management system and an administration system.QUESTION: Are all these functions missing from the existing systems (GCNet and West Blue platforms)? Aren’t these functions an integral part of the existing single window and not an addition?QUESTION: How much, percentage wise, are revenues likely to increase from the existing situation with the new system? Will this be large enough to offset the potential loss revenue from government shareholding in GCNet?
2. We note that in 2017, the Customs Division was given a target of GHc13.9bn and ended up collecting GHc12.6bn representing 91% for government. This is evident in the dividends GCNET pays to government on a yearly basis. (Sourced: GCNET Dividend Payout from 2002-2017)⦁ QUESTION: Isn’t 91% revenue turn out under the existing system significant? Why shut down existing successful systems and incur huge costs in judgement debts and in the acquisition of another technology?
3. In September 2018, DANIDA, a project sponsor recommended that after the January 1, 2019 start date of UNI-PASS, there should be an 18 month development, installation and configuration period.QUESTIONS:
   ⦁ Is this being done?
   ⦁ What will the transition look like and what consequences will it have for trade facilitation and revenue mobilisation?
4. Separate reports have stated that GCNet charge importers a fee of 0.4% on FOB, while West Blue charge between 0.28% and 1% for CIF. Combined import fess on FOB for West Blue and GCNet therefore is 0.68% . UNI-PASS is charging $40M plus 1% interest for 10 years.QUESTIONS:
   ⦁ How do the combined charges of GCNet and West Blue compare with that of UNI-PASS at 0.75%? Isn’t this financially over burdening the importer?
   ⦁ Why is government awarding a higher contract rate for a longer period of 10 years?
   ⦁ What review processes has the Ministry of Trade carried out recently (can evidence be adduced) to justify the signing of this agreement?
   ⦁ Can MoTI share the results of the feasibility studies (2015) on the ports, conducted by CUPIA of Korea Customs Services and Ghana Link Network Services,the very companies that have been sole-sourced to cancel existing contracts at huge costs?
5. We note that a plethora of initiatives have been introduced to streamline port operations. The latest is the Cargo Tracking Note (CTN).QUESTIONS:
   ⦁ Where is CTN system in all this? Are they being maintained and who is paying for it?. How much is it costing the government?

On Monday this week, IMANI delivered 275 individually addressed letters to Members of Parliament on how Ghana’s trade flow could be disrupted due to the introduction of yet another similar technology at the ports. IMANI has been working on trade facilitation issues for years.