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General News of Sunday, 27 May 2018


IMANI working against Ghana – PNF

Pressure group, Progressive Nationalist Forum (PNF), has accused IMANI Ghana and telecommunication company, MTN, of working against the state with regards to the $178m KelniGVG deal signed between the Government of Ghana and Haitian firm KelniGVG.

Mr Fanklin Cudjoe, President of IMANI has been vociferous in condemning the revenue assurance deal which is meant to monitor revenue in the telcos industry.

Although the government insists the deal saves the country $1.1 million a month, Mr Cudjoe wonders why the state has been paying the firm $1.5 million per month since January for “no work done”.

To Mr Cudjoe and IMANI, the deal is “needless” and a rip-off.

But PNF in a statement agreed with government that the deal is in the best interest of Ghanaians and wondered why “any patriotic Ghanaian, or for that matter good cooperate citizen will be against an auditing system that seeks to bring transparency and enable government collect taxes due it.”

Below is the full statement from PNF


The Progressive Nationalist Forum has followed with dismay, the pedestrian issues raised by Imani Africa in general and Mr. Franklin Cudjoe in particular with the help of the CEO OF MTN Ghana against the government policy on the Common Platform for Telecom Revenue Assurance and Regulatory Oversight.

1. The CP as is commonly known takes its locus from the communications service tax (amendment) Act, 2013, Act 864 (amendment of section 14 of act 754) which enjoins the minister of finance to collaborate with the minister of communications to inter alia:

a. Establish a mechanism to verify the actual revenue that accrue to vendors for the purpose of computing taxes due the government under this act;

b. Be given physical access to the physical network nodes of the vendors network at an equivalent point in the network where the network providers billing systems are connected and

c. Ensure that a common platform is used for the purpose of verifying revenues under the act as well as the revenues accruing to levies under the electronic communications act 2009, (act 775).

From the above narration, the action of the minister of communications, the finance minister, GRA and NCA are in conformity with the laws of Ghana.

We have also seen and evaluated the key performance indicators for KelniGVG which include but not limited to the following:

a. Provide on real time basis, accurate measurement of the types of traffic:

1. Volume of international incoming traffic terminated in Ghana

2. International outgoing traffic originated from Ghana

3. Domestic (on-net and off-net ) voice traffic in Ghana

4. Data traffic in Ghana

b. Generate daily, monthly, quarterly and annual statistic on international incoming and outgoing traffic volumes, classifying the volumes by operators and carrier links

c. Generate daily, monthly, quarterly and annual statistics on local on-net and off-net traffic volumes, classifying the volumes by operators.

d. Enable the comprehensive and accurate billing of the governments share on the international incoming traffic termination (set at USD 0.06)

The above KPIS from our point of view will assist government in collecting the accurate revenues from the various telecom operators in the following ways;

a. KelniGVG will be able to monitor and provide the exact amount of revenue generated from mobile and fixed lines network operators as well as broadband wireless access licensees.

b. Generate daily, monthly, quarterly and annual statistics on revenue generated from telecommunications services based on;

1. Prepaid services (sms, voice, data)
2. Post-paid services (sms, voice, data)
3. Value added services
4. Wholesale services
5. Other telecommunications service

On the issue of mobile money transfers and revenues generated therein by the operators, KelniGVG will be able to capture the following:

a. Mobile money transaction data to establish as a minimum the total value of authorised e-money in the market and the fees accruing to each operator on a monthly basis. This should enable government know exactly what amount comes to it as tax revenue from the profits made by the operators.

b. They will be able to provide government with comprehensive statistics on transactions, including but not limited to:

1. Cash in
2. Cash out
3. Fee associated with transactions
4. Peer-peer transactions
5. Total volume of transactions by operators
6. Total value of transactions by operators.

c. Provide the above on daily, monthly, quarterly and annual basis.

The above is all to be done by KelniGVG on real time basis. Which means that the company will collect the exact information as the operators collect from the same source thereby limiting the ability of the operators to tamper and manipulate data to their advantage before passing it on to tax authorities? This was what was done under Subah and Afriwave, which the new system seeks to change.

On the matter of effectiveness of the common platform to monitor mobile money transactions, we found out that the system is capable of collecting data on all mobile money transactions for regulatory oversight, consumer protection and anti-money laundering purposes. It is very relevant to note that terrorism especially in the sub-Saharan African region has been largely financed through the use of mobile money transfers. Examples abound in Nigeria, Somalia, Niger and Mali just to mention a few.

A responsible government cannot afford to leave this area unchecked and to the whelms and caprices of telecommunications companies whose main motive is profit making. With porous physical borders as we currently have, we as a nation cannot afford to leave the cyber space to terrorist to operate.

Government loses millions of dollars every year to simbox fraud and if the telecommunications companies are not complicit in these activities, we do not understand why they will be against any system that will help arrest the situation and make sure all amounts and taxes due to government are properly collected. To this effect the new system is capable of doing the following;

a. Able to manage the tracking of international call termination, on sample basis, to detect and report the by-passing of the legally declared routes for international traffic into Ghana and to assist in blocking such numbers. By-pass calls include international PSTN calls terminating on an OTT voice application such as viber.

b. Able to localize suspicious and/or fraudulent SIM and equipment using available information from operators, including by-pass traffic information and other network elements, to search for and locate illegal SIM-BOX operators.

c. Provide the above statistic on daily, monthly, quarterly and annual basis.

Apart from the above, individual consumers stand to gain directly from the new CP in the following ways;

a. By tracking and eliminating fraudulent traffic (simbox) the CP will make networks more secure for everyone.

b. The elimination of fraudulent traffic will also improve quality of service on international calls, since calls going through illegal routes are of poor quality due to the VOIP compression methods used by the fraudsters.

c. The CP will enable a more proactive approach of consumer protection, not based only on after the fact complaints management, but on real time data collected and analysed by the NCA.

d. The CP will yield the same benefits as the above mentioned ones for mobile money subscribers, bringing more security, reliability and transparency in the mobile money industry. This is a clearly significant component of the CP considering the rising trends in financial crimes and terrorism financing. For example, in Tanzania, nearly half of its GDP value is transacted through Mobile money platforms. Monitoring of Mobile activities is only possible through much more visibility than what is currently in place to protect the general public from market failures, which can have serious economic implications for Ghana. Traditional banks have been closely regulated over the years to protect consumers, but due to informality of the users and intermediaries in the mobile money ecosystem, it is imperative that as the Technical Regulator, NCA puts in place such monitoring to provide useful information to the Government of Ghana to help protect the public.

The PNF has also questioned why the NCA has not taken up this CP system and implement by itself. It is clear that the NCA as it currently stands does not have both the financial capacity and technical knowhow to implement the system on its own. Currently, NCA personnel are being trained abroad to enable them do proper evaluation and assessment of the data that will be provided. It is the hope of the NCA that at the end of this contract, its staff would have acquired the requisite capacity to continue the CP.

We are aware that the new company has invested not less than 60million USD so far in in equipment, software, capacity building among other things for the smooth take off of the system. The total pre-financed hardware and software costs excluding operational and maintenance costs is valued at over $62 million with the responsibility to guarantee the upgrading and updating the CP Solution resting with KelniGVG. It is therefore palpable falsehood being peddled by the assigns of some of the telecoms companies who don’t want this implemented, that claim that the current system can be done for a paltry sum of 200,000 USD. We challenge them to strict prove.

From the above narration of what the facts are about the new system, PNF wonders why any patriotic Ghanaian, or for that matter good cooperate citizen will be against an auditing system that seeks to bring transparency and enable government collect taxes due it.

We wish to use this opportunity to ask the government through the minister of communications and the NCA to cause a forensic audit into the operations of MTN over the past years to find out what it is they did in the past that they fear the new system will expose.

Finally, we pray the government, through the minister of communications and the NCA to ensure strict compliance to the KPIs and license requirement of the operators to ensure an improved service delivery based upon which their licenses should be renewed or denied in 2019.

Richard Nyamah