Adam Smith International (ASI) is the chosen Service Provider (SP) for UK’s Department for International Development five-year Strengthening Action Against Corruption (STAAC) programme. The programme works to strengthen institutions and organisations in the anti-corruption chain through the design and implementation of pragmatic and scalable interventions. STAAC focuses on designing pragmatic interventions across the functional anti-corruption chain, rather than the traditional donor emphasis on funding institutions. It is both easier and more pragmatic to identify the functions that are essential for a more effective anti-corruption chain: detection and investigations; prosecutions and adjudication, enforcement and asset-tracing and recovery; and public information. As such, STAAC will be working with a range of institutions including the Financial Intelligence Centre (FIC).
The FIC has recently implemented the Anti-money Laundering solution goAML which is a product of the United Nations Office on Drugs and Crime (UNODC). As part of the FIC transformation process, a set of four data enrichment interfaces to enrich the collected data by the FIC on Suspicious Transaction Reports is required.
Job Title: Interface Developer
The data enrichment interfaces should be developed and implemented as per the attached specifications.
ASI is hereby seeking interested qualified providers to submit a technical proposal and a financial proposal to supply the required services including a project delivery plan.
The solution must automatically or upon a goAML user request query select government databases for targets of interest of the FIC and fetch matching data and integrate seamlessly into the goAML database.
The proposed solution must adhere to the following requirements:
- The request for initiating data collection must be intiiated from the goAML GUI on persons and legal entities.
- The request for initiating data collection must be triggered upon receipt of STR and CTR automatically to all interfaces. This option must be subject to a configuration to be turned on/off by goAML administrator.
- The solution must strictly adhere to the current goAML security architecture which splits the solution into different security and network zones. Furthermore, it must encrypt all communication between the different zones and utilize mutual authentication between all components.
- The solution must provide web-based GUI for full solution administration.
- The solution must be configurable to define the matching criteria between the subject of interest from the FIC side and the government database being queried. This configuration must be flexible to allow for exact as well as approximate match. In case of a partial match, the solution must preserve the existing data and link it to the searched target of interest and provide information to trace the match within the journaling mechanisms of goAML.
- The retrieved data must contain all unstructured documents available in the queried database (PDF, IMAGE FILES, etc..) and attach it to the person files or entity files in goAML. In addition, a journal entry summarizing all relevant facts found in the searched government database must be created and linked to the search target of interest.
- A report within goAML must be created to show the searches done, results retrieved and date/time stamp for the request sent and the date/time stamp for the response received.
- All retrieved data must respect the data model of goAML in order to preserve all the functionality of goAML in terms of search, BI, statistics, reporting, visualization etc..
- The solution provider must demonstrate a working knowledge of goAML and systems integration by providing reference to similar engagements with goAML.
- The four interfaces to be implemented must be chosen out of the following list at the time of implementation in consultation and agreement with the FIC and STAAC team:
- Ghana Revenue Authority (GRA): The data retrieved from the GRA would serve in detecting possible tax evasion cases as a predicate AML offence, as well as shedding light on the commercial activities of the subjects of interest under intelligence analysis. The data will include the complete annual returns statement with the breakdown of the sources of income.
- Registrar General (RG): The registrar general databases will be queried by using the following criteria:
- Person ID: To retrieve all companies registered where the person of interest has shares or sits on the executive board. The company information will be a complete record of the commercial registration and all identification documents submitted to identify the shareholders.
- Company registration number/company registered name: The data retrieved will be a complete record of the commercial registration and all identification documents submitted to identify the shareholders. Furthermore, the FIC will get the registered commercial licenses for the company that show its line of business and its registered capital.
- Real Estate registrations will also be retrieved for persons and legal entities.
- The above searches can be iterative in the sense that once the FIC retrieves the list of shareholders, they use their information to query the database again for other possible registrations for the shareholders to formulate a comprehensive view of all companies registered and to reveal the true beneficial owners that might be hidden through company hierarchies. A configuration setting must be available to allow for this iterative search to be conducted automatically.
- National Health Insurance Authority (NHIA): The NHIA database will be queried for the national health card and a copy of it will be obtained to be stored into goAML. In addition, a list of co-insured family members will be retrieved to establish the family tree and identify any assets registered to family members.
- National Identification Authority (NIA): The database of the NIA will be queried for the national ID card and a copy of it will be retrieved to verify the identity of the person of interest.
- Immigration Service (IS): The immigration database will be queried for foreigners to get a copy of their passports used to obtain visas and residence permits. In addition, the database will be queried for passenger name records (PNR) to identify movement of persons of interest across international borders and destination countries.
- Driver & Vehicle Licensing Authority (DVLA): The database will be queried for registered vehicles to assist in wealth determination. In addition, the database will be queried for driver license information and a copy will be retrieved for identity verification of the person of interest.
- Passport Office: For Ghanaian nationals, the passport office will be queried and a copy of all issued passports will be retrieved to verify the identity of the person of interest.
- Customs: The customs database will be queried for customs declarations made by individuals and legal entities to determine commercial activity to assist in wealth determination, relationships on the reginal and international levels and to assist in identifying trade-based money laundering and possible tax evasion cases.