“We have got the National Identification Authority which sits as our repository of National Data. It was the wickedness of the highest order to subject Ghanaians to long hours of queues, taking productive man hours affecting our economy, just to go and queue again and resubmit biometrics;” words of Ghana’s Minister of Communications Digital Technology and Innovation Sam Nartey George at his vetting before parliament on January 30, 2025.
Samuel Nartey George remains resolute in his convictions after he commanded what came to be known as the stubborn Academy in October 2021, when his predecessor Ursula Owusu-Akuful gave directives for the commencement of a SIM Card Reregistration exercise with the Ghana Card (Ghana’s Official National Identification Card) as the primary identity document for registration.
Aware of the dreaded sanctions for all unregistered SIM cards to be blocked by the night of 31st March, 2022; several queues begun building up in offices of the National Identification Authority and designated offices of the Mobile Network Operators with crowds reaching their peak when the deadline drew closer.
While many Ghanaians protested the action, blaming the National Identification Authority for its failure to issue them cards; the sector minister was forced to extend grace periods with subsequent lines of action effectively deactivating services in a graduated punitive regime to get the stubborn academy to submit their SIM cards for registration.
Five years on, Ghanaians were virtually dazed to hear the legislator Sam George appear before parliaments Vetting and Appointments Committee to announce yet another round of SIM card re-registration exercise.
He was however quick to proffer further clarity that assuaged the shock that was boldly written in the faces of the vetting panel; and the millions who followed the proceedings from mass and social media platforms.
The Hon. Sam George explained that this move which would not encumber the public to suffer long queues will help build a full proof biometrically verifiable SIM Card Registration Database which can be cross referenced with Ghana’s National Identification Database.
He was optimistic the security services could now, more than ever, seamlessly identify whoever was using a SIM card to commit mobile money fraud, a problem which has become an albatross around the necks of the Mobile Network Operators (MNOs) and Security Services alike.
“In the case of mobile money fraud, we need to work collaboratively with the MNOs and that is why we need to get back to the SIM re-registration again, to properly register the SIMS. The MNOs should be able to tell who is holding the SIM. It is one thing blocking the SIMS and it’s another thing tracking the cartel behind it, arresting them and prosecuting them,” he asserted.
In this article; I PROVIDE a background about the severity of Mobile Money Fraud in Ghana; I explore how this proposition is consistent with the global concept of Digital Public Infrastructure (DPIs); how it supports the ambition to weed out fraudsters and how it has opened up the discussion among the Ghanaian Tech Community; the Ghana Telecoms and Electronic Money Issuers Chamber, Mobile Money Agents and the end users.
Severity of the MOMO Fraud
Ghana’s Mobile Money industry continues to receive global plaudits ranking it the best in the world in Mobile Money Regulation according to the 2024 GSMA Mobile Money Regulatory Index (MMRI).
Driven by the Mobile Money Interoperability (MMI) platform owned and regulated by the Central Bank through the Ghana Interbank Payments and Settlement Systems (GhIPPS); Mobile Money has accelerated Financial inclusion moving the nation from a 70% unbanked population in 2023 to over 90% presently.
Even though Ghana achieved perfect scores in Transparency and Disclosure Requirements, Authorization, and Consumer Protection ON THE global MMR Index; the country continues to bleed profusely through mobile money fraud affecting both customers and agents alike.
Statistics of Fraud
The Banks, Special Deposit-taking Institutions (SDIs) and Payment Service Providers (PSPs) Fraud Report released annually by the Bank of Ghana (BoG) provides updates on fraud occurrences and trends recorded from the various players in the sector.
in 2022 there were 2,998 cases of attempted fraud for the banking and SDI sector, compared to 2,347 cases in 2021, this represented a 27.74% increase.
It translated into financial institutions in the country losing GHS82 million in a total of 15,164 fraud incidents during the course of the year.
The total comprised of GHS56 million lost to fraud in banks and Special Deposit-taking Institutions (SDIs), and GHS26 million lost in the form of e-money (including mobile money) via payment service providers (PSPs) – including mobile money operators.
The count of fraud cases increased to 15,865 in 2023 from 15,164 in 2022, reflecting a 5% rise.
Banks, Special Deposit Institutions and Payment Service Providers comprising Mobile Money Operations recorded a total loss value of approximately Gh¢88 million in 2023 as compared to GH¢82 million in 2022, indicating an increase of about 7%.
The DPI Argument;
Digitization and artificial Intelligence have headlined the next phase of enablers actively and disruptively dictating the pace of development and governance across the world.
Concerns around how governments buy into these systems, build the digital framework for their citizens to safely tap into the digital revolution and how governments are able to use these same secure systems to better identify and provide developmental interventions and society wide solutions have engaged global leaders culminating in the umbrella model of Digital Public Infrastructure (DPI).
The broad concepts of generating unique digital identification databases for citizens; creating digital payment platforms and building open source systems that data share and its attendant concerns of inclusivity and data security have been accepted as major building blocks for DPIs.
The concepts have now directed discussions about accountability to not only focus on how a country spends on and handles its Physical Public Infrastructure but also, how a state invests in, handles and protects its investments in Digital Public Infrastructure.
Digital Public Infrastructure has further gained momentum following successful stories about how countries like India and Estonia used their DPIs namely Aadhaar and X-ROAD to leap frog its development exponentially in areas of making digital payments, offering private and public services and deepening transparency and accountability.
Cross Roads between DPIs and Momo Fraud Fight.
For low and middle Income Countries Ghana included, Digital Public Infrastructure that enables the building of open source, scalable, Digital Public Goods provide an enabler that can be leveraged to solve a myriad of development challenges and to provide solutions in a manner that accelerates the country’s sustainable development aspirations.
While Ghana’s SIM Card Registration rode on the National Identification Authority Database which has become Ghana’s most successful foundational DPI, it failed the data sharing checklist creating separate biometric databases that could not cross-reference each other.
This assertion which was tacitly admitted by Minister of Communications; Digital Technologies and Innovation Sam George has been corroborated by the Chief Executive Officer of the Ghana Telecoms and EMIS Chamber which acts as the advocacy spearheads for all Mobile Network Operators.
Ing Dr. Ken Ashigbey argues that the status quo which only allowed a first stage verification of personal details with the National Identification Authority and a final stage where the SIM card holder visits the MNO office to get their Ghana Card, Pictures and Finger Prints captured separately is not complete.
“I wouldn’t say it is useless. I would say it was incomplete. The thing about it is the fact that the biometric data that was collected was not reading properly.”
He explained that while the initial phase of SIM registration verified data against the NIA database, the second phase—biometric verification—was flawed as the MNOs could not verify the biometric data collected with the central database of the National Identification Authority.
“WE do the liveliness test, we do the likeliness test, we collect the biometric data, but we don’t compare it with the single point of truth, which is the NIA database,” he told journalists in Accra.
Extra Security Plugins under Consideration
On the back of the planned reregistration of SIM Cards which effectively and comprehensively synchronizes the database of the MNOs under the National Communications Authority and the National Identification Authority, several proposals have emerged with the aim of enhancing security and fighting Mobile Money fraud.
The Telecoms Chamber has proposed that the NIA can use its data sharing capabilities with other user agencies such as SSNIT, NHIA, GRA and the Controller & Accountant-General’s Department to deny services and state interventions to anyone found to have used a SIM card to perpetrate Mobile Money Fraud.
Explaining the possibilities to DPI Africa Journalism Fellows; Ing. Dr. Ashigbey insisted, “We should be able to tie SIM Cards to multiple things such that if you are defrauded and you call your TelCo or Mobile Money Operator, they will investigate and block the SIM and the device the person used from their system. Then they will report it to another platform we are calling the FCD. On the FCD, all other Networks will block the device from registering any SIM on their various platforms.”
“We are then getting to the point where we blacklist the ID the person used. So that the ID cannot register a SIM card again. We will bring in the banks and FinTechs to do that,” he divulged.
Deepening the punitive regime, Dr. Ashigbey suggested, “We must bring in the interoperability in such a way that if you go to the DVLA to register a car, you cannot do that; if you go to the National Health Insurance Authority to get an NHIS Card, you cannot register. We can even tie it to the ability to benefit from state interventions like Free SHS,”
He insisted that while the tech solutions existed it would take a governance and leadership style of sector leaders to properly implement the proposed solutions to secure the Mobile Money Landscape in a manner that makes it difficult for fraudsters to have a fields day.
The Minister of Communications Digital Technology and Innovations has already given the strongest indication that his ministry is pushing for an enablement to block devices used for perpetrating SIM Card Fraud.
Sam George clarified in a subsequent interview on Joy News; “Now we are not just doing SIM Card re-registration. We are doing a Central Equipment Identity Register. Every Phone has an IMEI which is an equipment identification number. There is a global database and now we are tying your SIM cards with the phones that you use.”
“We are then able to track substandard equipment; equipment used for fraud and block them. If a phone is used to commit fraud; I can block that sim and block that phone as well. Otherwise, the person can just get another SIM and drop in the phone,” he elucidated.
CSO and Tech Community Buy In
Strategic Thinkers Network Africa STRANEK Africa a civil society organization which played an oversight role over Ghana’s digitalization agenda has been critical about the processes, data protection safeguards and the inclusivity of the Registration process since its commencement in October 2021.
Its Executive Director Nii Tetteh Tettey has welcomed the new directive to build a database that harmonizes data between the MNOs and the National Identification Authority insisting the move will bolster the resilience and integrity of Ghana’s SIM card Registration Database.
“From what I glean from the minister; it is to ensure that our SIM card registration data is full proof. It doesn’t leave room for any fraudulent activities. I think it is a good exercise.”
“This may be an intention to correct fake registrations. We know that with the Ghana Card, people are very careful in registering SIM Cards if they have any intentions of using them for fraudulent purposes because they know that they can be traced,” he explained.
Mr. Nii Tetteh Tettey however proposes that government explores the capabilities of Artificial Intelligence and Technological advancements to deploy the most cost efficient solution that will not require citizens queuing unnecessarily as happened with the initial re-registration exercise.
“The data bases are already there and the IT persons should be able to find a way of synchronizing the two instead of asking us to go queue again because that will cost a lot of time and money. When the databases are put together we can detect which once are repeating themselves and in this time of technology and AI, this is not an impossibility at all,” he suggested,” he cautioned.
Public Concerns.
The information about the pending exercise which the sector minister terms a re-visitation of SIM card re-registration has widely suffered distortion and misunderstanding among Ghanaians.
“Under President Rawlings, we joined queues for a voters’ register exercise; we did same under President Kuffour; we joined queues under John Mahama. Under President Akufo – Addo, it was worse and they expect us to go join ques again,” Paa Kwesi Dadzie fumed when asked what he heard and understood about the minister’s announcement.
This reaction run through a majority of the comments partly because of the captions from media houses that flooded social media shortly after the minister made the comments.
“I heard that there is going to be another SIM card registration but I heard the minister say there will not be queues. We will do it from our phones. I hope it is true because I will not be ready to go queuing again,” a better informed Abdul Wahib Yakubu told reporter Iva Heathcote – Fumador.
“How can we be sure that this will help arrest the fraudsters? Because we were told same when we went to do the re-registration but the fraudsters are still operating freely. A colleague of mine fell victim twice last year alone,” a doubtful Usman intimated.
The Minister of Communications, Digital Transformation and Innovation Sam George, has had course to diffuse the notion that people will be required to go back to registration centers to provide a fresh set of information for a new SIM Card re-registration exercise.
Speaking on News File on Joy News he insisted, “We will do a proper SIM re-registration again, and this time, there will be no queues because common sense will prevail, and we will use technology to do it.”
Continental Fraud Management Support Systems
The Annual State of Inclusive Instant Payment Systems (SIIPS) report released by the Africanenda Foundation provides players, regulators and stakeholders in the Instant Digital Payments Sector a comprehensive view about trends, developments and challenges with the aim of fostering growth, strengthening regulation and promoting inclusion in the IPS ecosystem in Africa.
Cyber Security and Fraud constituted one of the major concerns when it held a comprehensive conference in Ghana to herald the launch of its SIIPS 2024 report attended by Central Bank Governors; Fintech Players; Managers of Instant Payment Switches and Fintech moguls across the African Continent.
Addressing a news conference, Deputy CEO for Africanenda Akinwale Goodluck disclosed a series of cross border collaborations working to help individual countries in Africa strengthen the Cyber Security space against all forms of fraudulent operations including Mobile Money fraud.
“On the operational side, Africanenda is supporting the deployment of very versatile fraud management systems that are open source and maintained locally, ensuring that the systems are designed bespoke for the kind of fraud that we are seeing on the Continent. Africanenda is working at ensuring that the Fraud Management Systems are not vendor locking such that when you have a problem, you have to call people in different time zones and you don’t have to pay a lot of money in annual licenses and you don’t pay a lot of money for upgrades,” he noted.
The 2024 SIIPS report featured evolving developments in FinTech licensing regimes, and eKYC systems exploring the role of Instant Payment Systems in advancing digital public infrastructure (DPI) initiatives across Africa.
Conclusion:
In conclusion; the Digital Public Infrastructure approach and its potential for providing society wide solutions in an inclusive, equitable, safe and properly regimented manner that lends itself to data sharing, and reusability for different relevant organizations for a wide range of purposes is showing more prominently in Ghana’s DPI discussions.
Ghana will have to draw valuable lessons ensuring that data on unique digital identities are no longer collected in Silos of different state agencies which will occasion another costly exercise to synchronize especially when the Laws that establishes the National Identification Authority; mandates it to be the ultimate repository of validated and verifiable identity information of Ghanaians and all permanent foreign residents.
This article is produced under the Digital Public Infrastructure (DPI) Africa Journalism Fellowship Program of the Media Foundation for West Africa and Co-Develop.
