FIC’s Transformation: From Barely Performing to Key Government Instrument
Accra, Ghana - In a remarkable turnaround, the Financial Intelligence Centre (FIC) of Ghana has undergone an irreversible transformation from a barely performing organization to a key government instrument for detecting financial crime.
Turning Around a Struggling Organization
The FIC’s transformation was made possible through the introduction of new processes and upskilling of key staff, resulting in significant improvements in the speed and quality of responses to requests for information from Law Enforcement Agencies (LEAs). The FIC also began tracking registrations of new reporting entities and creating compliance risk reports for supervising agencies.
Key Improvements
- Instantaneous data acquisition: By 2020, the FIC was able to add significant value through instantaneous acquisition of data from multiple agencies.
- High-quality case referrals: The investment in merging the FIC’s database with other government databases enabled meaningful analysis of financial crimes, suspects, witnesses, evidence, and assets.
- International cooperation: The FIC’s new capabilities facilitated high-quality case referrals to foreign Financial Intelligence Units (FIUs), enabling international cooperation in combating financial crime.
Lessons Learned
The transformation of the FIC was not without its challenges. Change management needs to be integrated into broader organizational work to support transformation from manual to automated environments. Better and more effective change management activities could have resulted in earlier and better outcomes.
Additionally, there can be no AML/CTF without adequate resourcing. Despite the pressing concern of addressing FATF requirements, the FIC continues to face resourcing issues, including staff numbers and quality, infrastructure support, and limitations in authority to compel compliance from accountable institutions and other reporting entities.
Building Trust-Based Partnerships
STAAC’s initial engagement strategy was largely responsible for its successes in the FIC. By creating conditions for a genuine partnership and shared work plan under the framework of a strategic plan, STAAC advisors became deeply embedded within the FIC operational and leadership environment. This allowed for adaptation of the intervention portfolio as needed, hands-on support to analysts, and continued commitment to STAAC by the FIC in the face of external shocks.
Areas for Further Support
There remain issues to be addressed in the arena of regulation and reporting on Mobile Money, a means to transfer money and value using telecom operators. The mobile money operators are currently regulated under the Ministry of Telecommunication, but there is a need to change the administrative framework to regulate Mobile Money as a Money Value Transfer Service (MVTS) under the Bank of Ghana.
Regulations must be amended to force all MVTS to report low threshold transactions to the FIC. There is also a need to support the FIC in creating special purpose tools to detect patterns in Mobile Money transfers in/out and within Ghana. Currently, it is estimated that 60% of all Ghanaian payments are done through mobile money and continue to grow logarithmically year on year.
The success story of the FIC’s transformation serves as a testament to the importance of effective change management, trust-based partnerships, and adequate resourcing in achieving significant improvements in combating financial crime.