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www. intracom. dk Risk Management within the Context of Integrated Border Management – Some Considerations WCO ICT Conference - Seoul, 25. April 2008 Copyright © 2008 Intracom IT Services. All rights reserved. 1

Intracom IT Services • Formerly Compliance Solutions Department of WMdata • Recently acquired by Intracom IT Services • Considerable experience (more than 19 years) in compliance and enforcement domain • Complete business solution and methodology for compliance and enforcement • Considerable customs experience in general, inter alia, as one of the main suppliers to EU Customs Directorate (DG TAXUD) • Key player in other customs areas (e. g. NCTS) Copyright © 2008 Intracom IT Services. All rights reserved. 3

Intracom IT Services References ü more than 30 customers in over 25 countries on 5 continents ü both customs and tax ü from small administrations to very large administrations ü from single applications to comprehensive, integrated compliance solutions ü from basically compliant cultures to highly non-compliant cultures Copyright © 2008 Intracom IT Services. All rights reserved. 4

Integrated Border Management What is it? • • Across/between countries Across/between agencies Across regimes - people and goods Across/between processes – before, – At, – and beyond the border Copyright © 2008 Intracom IT Services. All rights reserved. 6

Integrated Border Management And what does it that imply? • Combining organisations • Combining functions (goods + people) • Integrating processes • Sharing and/or integrating systems (Single Window) • Sharing and/or integrating data • Sharing knowledge Copyright © 2008 Intracom IT Services. All rights reserved. 7

Integrated Border Management But what does it really mean? • Managing the RISK in the light of the prevailing circumstances – Inceasing (and more highly organised) • threats to security • avoidance & evasion – Ever more pressing need to facilitate trade • In an integrated manner Copyright © 2008 Intracom IT Services. All rights reserved. 8

Integrated Risk Management What are the barriers to implementing IRM • The potential scope • Laws (e. g. protection of the individual’s rights) • Budget • Unwillingness to cooperate – political level – operational level • Lack of capacity • Lack of expertise • Limited vision Copyright © 2008 Intracom IT Services. All rights reserved. 12

Integrated Risk Management Limited Vision • too much focus on clearance • data ’bandwidth’ is too narrow • too much focus on known risk factors (e. g. risk profiles) • risk management as only ”identifying and quantifying” risk Copyright © 2008 Intracom IT Services. All rights reserved. 13

Integrated Risk Managment • Recognising and understanding potential sources/areas of risk • Determining policy for addressing risk • Identifying risk (within these areas) • Quantifying risk • Addressing the risk (in a prioritised fashion and in conformance with the policy) • Monitoring the effect Strategic Level Operational Level (Risk Analysis) Management of the total risk faced by the organisation Copyright © 2008 Intracom IT Services. All rights reserved. 14

Integrated Risk Management So where does that leave us • Be pragmatic – start small and proceed incrementally but in relation to an overall strategy • Must consider all the steps • Start internally and proceed outwards • Work simultaneously at level of: – business processes (before, at and beyond the border) – data (enhanced availability and access) – systems (to support the procedures and optimise use of data) Copyright © 2008 Intracom IT Services. All rights reserved. 15

Recognising and Understanding Risk Causes of Risk • Laws • Administrative procedures • Socio/economic situation • Political situation • Attitudes • . . . Copyright © 2008 Intracom IT Services. All rights reserved. 17

Recognising and Understanding Risk Where do we encounter risk • At any stage of the interaction with the trader (or passenger) – – – In the goods clearance process During audit During collections Coincidentally (ad-hoc) Directly Indirectly Copyright © 2008 Intracom IT Services. All rights reserved. 18

Recognising and Undestanding Risk How do we encounter risk • Incorrect reporting – False/erroneous – Partial reporting – Under-reporting • Non-payment • Interaction with other agencies • Suspicious activities • Coincidentally • In other connections Copyright © 2008 Intracom IT Services. All rights reserved. 19

Recognising and Understanding Risk management is directed at: • the voluntarily compliant – informative (pro-actively help them to avoid mistakes) – corrective (re-actively helping them to understand correct unintended errors) • the non-compliant – preventive (keep them from deviating by sending a strong signal) – corrective (taking punitive action based on targeted identification) Copyright © 2008 Intracom IT Services. All rights reserved. 20

Determining Policy for Risk Depends on organisational strategy • • Maximise revenue Reduce crime Reduce corruption Improve security Improve voluntary compliance Improve service (trade facilitation) Etc. Copyright © 2008 Intracom IT Services. All rights reserved. 21

Determining Policy for Risk How Do We Organise Against Risk • Internationally/Nationally • Centrally/Regionally • Separately within domains (excise, security, clearance, post clearance, intelligence, goods, passengers) • Integrated across domains • … Copyright © 2008 Intracom IT Services. All rights reserved. 22

Determining Policy for Risk How Do We Eliminate/Reduce Risk • • • Coercion Service (making it easier) Incentives Information and education (of the public) Psychology Increasing the likelihood of detection Competence building Collaboration Technology Copyright © 2008 Intracom IT Services. All rights reserved. 23

Risk Analysis At the operational level risk management involves: • identifying the risks • evaluating the degree of risk • determining the necessary corrective actions to address the risk and the appropriate level of resources necessary to do so • confirming the risk • monitoring the efficacy of the actions Copyright © 2008 Intracom IT Services. All rights reserved. 26

Identifying and Quantifying the Risk • Start by developing an overall risk model • And ensure an approach that: – Adresses all the different occurences of risk – At every level of interaction with the trader, broker, passenger, … – Is integrated across points of contact – Is quantifiable and objective – Is flexible – Has a high degree of granularity (segment orientation) – Can be integrated into the overall IT environment Copyright © 2008 Intracom IT Services. All rights reserved. 27

Indentifying and Quantifying the Risk To get the answers that knowledge workers need, the risk management systems must have: 4 The right data (within constraints of the law) 4 Proper data structure 4 Enough detail data 4 Enough computer horsepower Copyright © 2008 Intracom IT Services. All rights reserved. 28

Identifying and Quantifying the Risk Core Processing Systems Results Information External Sources (TPI) Ancillary Info DATA WAREHOUSE Government Agencies (TPI) Data Availability & Accessibility Departmental Systems PCA Selection Trader Profiling Intelligence Declaration Screening • A central repository • A single view of the trader • Single point of contact • Easy, controlled access • Modeled for analytical use Copyright © 2008 Intracom IT Services. All rights reserved. Research Decision Support Audit 29

Identifying and Quantifying the Risk • Data is only the first step - the question is how to get the most out of the data • A number of different analytical tools and methods are available • The choice of tools must match the needs of the application area - certain tools are suitable for certain types of analysis but not for others Copyright © 2008 Intracom IT Services. All rights reserved. 30

Identifying and Quantifying Risk We need to be able to support both transactional and behavioural risk analysis • Transactional risk analysis (real time) – – Declaration screening • import/export/transit declarations • pre-arrival information (manifest etc. ) Passenger screening Screening of suspicious activity reports etc. • Behavioural risk analysis (batch-oriented) – – – General risk profiling (traders, passengers) • certification (AEO, etc. ) • case selection (post clearance audit, criminal investigations) Risk analysis of financial information (during audit) etc. Copyright © 2008 Intracom IT Services. All rights reserved. 32

Identifying and Quantifying Risk Methods • Data Mining - for detection of hitherto unknown patterns and hypothesis generation • Knowledge-based Analysis – for identification and quantification of the risk - reasons on the basis of a set of rules which are derived from both human knowledge and experience and from the output of data mining • Need a formalised approach for verifying and transforming the hypotheses of the data mining approach to the grammar of the knowledge-based system Copyright © 2008 Intracom IT Services. All rights reserved. 33

Managing and Planning the Corrective Action Assignment Inventory Inspection/ audit or investigation Analyst Results Risk Analysis • Review results • Make final selection • Create assignments Trader Data Copyright © 2008 Intracom IT Services. All rights reserved. 35

Control Support q automation tools • case administration • data transformation • form filling support • spread sheet facilities • table management • note-pad • report generator • communication q analysis tools • account analysis • systems analysis • transactions analysis • audit planning • expert analysis • decision support Data Transformation . . Case Administration Planning Systems Analysis Reconciliation, X-checking Financial Ratio Analysis Expert Analysis ESKORT Integration with x-action level Office automation - spread sheets/tables - check list/note pad - word processing/report generation Laws, Regulations Instructions Copyright © 2008 Intracom IT Services. All rights reserved. 37

An Integrated Risk Framework Pre-arrival information Import/Expor Declarations Customs Clearance System Transactional Risk Analysis PCA Case Selection Behavioural Risk Profiling (Trader) Third Party Data Warehouse Intelligence Information Audit Results Inspection Support Audit/ Investigation Support Copyright © 2008 Intracom IT Services. All rights reserved. PCA Case Managem ent 38

The Next Step – A vision What next: developing a common language and grammar for expressing risk • developing a mechanism for transmitting risk information between shareholders • Developing a collaborative working model for risk – A risk clearing house? – Defining jurisdictions (international/ agency/ central/ local) • Copyright © 2008 Intracom IT Services. All rights reserved. 41