The Jamaica Customs Agency Needs a Risk Management System

This is a very interesting article for the international customs community.  The Jamaica Minister of Finance,  Audley Shaw expects to increase revenues from the Jamaica Customs Agency by up to 40 per cent with the implementation of new measures aimed at cutting down corruption and under-invoicing.  He plans to hold the Commissioner of Customs Major Richard Reese responsible for hitting that target.

First of all, that's a bit unfair.  Why? 

Because the government is setting an expectation that 2 recent technologies funded by the InterAmerican Development Bank (IDB) are going to help accomplish this, and that's simply not going to happen.  Especially since the Jamaica Customs Agency (JCA) and the IDB recently cancelled a tender for a Customs Risk Management System which was designed to accomplish exactly what the Finance Minister desires.

While the IDB funded for the recent deployment of a Port Community System (PCS) and the Automated System for Customs Data (ASYCUDA) from the United Nations Conference on Trade and Development (UNCTAD), neither system is capable of recouping an additional 40% in revenue evaded at the border.

Let's look at why this is the case.  A PCS is generally designed to share logistical data between port community stakeholders such as carriers, freight forwarders, and terminal operators.  Customs is often given access to the system to improve their supply chain domain awareness, but it is not a system that is designed to flag high risk shipments for evasion of revenue owed. It really just provides customs with better visibility into cargo moving through the port.

ASYCUDA on the other hand is a capable declaration processing system that can also perform accounting and payment functions for customs.  While UNCTAD will market the system with a risk management module, it is viewed by many as an entry level module and provides rudimentary functions.   I'd suggest that ASYCUDA is an "Automated System for Customs Data" and not an "Automated System for the Risk Assessment of Customs Data".  ASYCUDA is a fine system of record, but it is not capable of performing adequate risk analysis.  It's just not what it was designed to do.  It's a declaration processing system.  It's not a risk management system.  It's not a single window system.  It's not a port community system.  It's unfair to country members when a system like this is marketed as being capable of doing more.  This story line is a good example.

Neither the PCS or ASYCUDA is capable of meeting the task of rescouping 40% in additional revenue for Jamaica.  Holding the Commissioner of Customs accountable in this instance is a bit unreasonable and places Jamaica Customs at a disadvantage.  I don't see this desired outcome being realized with the technologies or capabilities currently in place. 

Regardless, here is how this can be resolved.  JCA and IDB actually held a tender for a risk management system in 2013.  This procurement was delayed and then cancelled in 2015.  Coincidentally at the same time of cancellation, IDB funded a "sole source" contract to UNCTAD for the implementation of ASYCUDA World.  No other system was considered or invited to bid. 

My view is this.  If the Minister wants to recoup 40% more in evaded revenue at the border, than JCA + IDB should consider re-activating the risk management tender and continue from where it left off.  These expert systems are specifically designed to identify high risk shipments for closer scrutiny or inspection.  A PCS and/or ASYCUDA is not.

Unfortunately, the situation becomes murkier still.  The World Customs Organization (WCO) has also recently deployed their "Cargo Targeting System" (CTS) in Jamaica as another sole source agreement without an open tender.  Funded by the U.S. Department of State, many feel this system is not fully mature or designed to identify high risk shipments for many threats, specifically those being fiscally related (e.g. undervaluation, mis-description, origin, smuggling, etc.)  In addition, the CTS operates on carrier data only.  Importer transaction data is not included within the analysis it provides.  The CTS is likely not going to be able to provide any assistance on the 40% target in my view.

Here's a question we all need to ask: Why are expert and advanced systems being blocked from the member nations who need it?  Why are the IGOs fostering 1) non transparent sole sourcing contracts or agreements for 2) rudimentary systems with 3) zero cost licensing when 4) procurement guidelines from key IGOs like the World Bank say otherwise?  Does anyone see the irony?  It's a problem only the member nations can fix.  Are they not in fact the IGO when combined?  Unfortunately, the secretariat in each IGO is not necessarily going to prompt this internal change without concern or the request formally tabled by the members.  As one technology vendor, I'd ask the IGOs to start thinking about this and guide your members accordingly.  There is a better way.

The current outcome isn't necessarily fair to a wonderful customs organization like the Jamaican Customs Agency, or the next international customs agency who will require an advanced risk management system.  There's a key piece of technology missing here.  Try and tell a modern administration like U.S. Customs and Border Protection that they have to recoup 40% more in evaded revenue without their Automated Targeting System (ATS).  The desired outcome cannot be achieved without the correct tool in the tool kit.  IDB has funded a toolkit for Jamaica.  It's simply missing the right tool for the job.  The Minister of Finance assumes that tool is in the bag.  It isn't.  Is anyone going to tell him?

The original article form the Jamaica Gleaner is posted below:

Minister of Finance Audley Shaw expects to increase revenues from Jamaica Customs Agency by up to 40 per cent with the implementation of new measures aimed at cutting down corruption and underinvoicing.
He will hold Commissioner of Customs Major Richard Reese responsible for hitting that target.
Sunday Business estimates suggest Reese would need to improve collections by up to $11 billion to deliver on the mandate. Implicit in the numbers is the cost the Government puts on port revenue leakage.
"I want revenue increases of between 20 and 40 per cent. That is creating equity in the tax system," Shaw said in remarks at the National Integrity Action (NIA) Roundtable on Curbing Tax Evasion last Thursday.
The Government of Jamaica in 2011 signed a series of agreements with the Inter-American Development Bank to automate a number of its procedures at the ports, including the Port Community System (PCS) spearheaded by Port Authority of Jamaica, the Automated System for Customs Data (ASYCUDA) system being roled out by Customs, and Revenue Administration Information System at Tax Administration Jamaica (TAJ), Shaw said.
The ASYCUDA operates as a web-based application for the payment of transactions. It aims to replace most paper-intensive processes with online procedures that will include payments, manifest submissions and declarations.
The PCS aims to create greater efficiency in the processing of shipments, through real-time access to information by stakeholders, including the Port Authority, Jamaica Customs, regulatory agencies and freight forwarders.
"When we combine ASYCUDA and the PCS and deliberately root out corruption at Customs, then, believe it or not, we can increase the revenue from Customs by anywhere from 20 to 40 per cent," said Shaw at the roundtable led by NIA Executive Director Dr Trevor Munroe.
"That is my target, and I am establishing that target with Major Reese publicly," Shaw said in a challenge to Reese, the commissioner of customs and head of the Jamaica Customs Agency, who attended the roundtable.
Efforts to clarify the timeline for the new targets were unsuccessful, but if the deliverables are supposed to be immediate, they appear to go beyond the figures contained in Budget documents tabled by Shaw in May.
In fiscal year 2015-16, the latest Revenue Estimates & Financial Statements (REFS) show Customs accounted for $29.5 billion of government revenue - which was a near ten per cent improvement on the previous year's performance. The target for this year is $33.5 billion, as stated in the REFS report, which implies expectations of a 13 per cent increase in customs revenue.
If the finance minister's instructions relate to this fiscal period, a 20 per cent increase over last year's intake would shift the Customs target to $35 billion. Hitting a 40 per cent target requires growing Customs revenue to $41 billion.
Instead of collecting $4 billion more this year, Reese is now being asked, it appears, to deliver between $6 billion and $11 billion more.
ASYCUDA is now 80 per cent implemented, said Shaw. The previous CASE system at Jamaica Customs operated with the myriad satellite applications that did not include the full functionality required of a state-of-the-art fully integrated customs management system. The ASYCUDA, provided through the United Nations Conference on Trade and Development, offers a more efficient technical solution.