The Importers and
Exporters Association of Ghana (IEAG) commends the Ghana Gold Board (GoldBod)
for the notable progress made in formalizing the gold trade, improving
traceability, and strengthening Ghana’s external reserves through structured
gold inflows. These reforms, widely referenced in public economic discourse,
are beginning to yield measurable macro-economic benefits.
Notwithstanding these
gains, IEAG, in fulfilment of its duty to protect legitimate trade and
investment, wishes to formally raise deep concerns regarding certain
operational practices of GoldBod that are increasingly constraining the
activities of licensed self-financing gold aggregators and exporters.
GoldBod was instituted
principally as a regulatory, coordinating, and oversight authority to curb the
illicit export of gold, particularly from the artisanal and small-scale mining
(ASM) sector, which publicly available data indicates contributes over 50 per
cent of Ghana’s total gold output.
While this mandate is
essential, IEAG is concerned that GoldBod’s increasing direct participation in
gold buying and exporting introduces a structural conflict of interest. The
current posture creates the perception of a regulator that is simultaneously setting
the rules, enforcing compliance, and competing commercially within the same
market space.
From a regulatory
economics standpoint, this arrangement undermines the principle of competitive
neutrality and risks distorting market outcomes. Analogously, it would be
untenable for the Bank of Ghana, as a regulator, to compete directly with
commercial banks, given its unmatched access to capital, information, and
regulatory leverage.
IEAG notes that while
over 200 aggregators have reportedly been licensed, only a limited number,
approximately five operate with direct financial backing associated with
GoldBod and the Bank of Ghana. Public reports further indicate that such
support includes interest-free or concessionary financing arrangements.
In contrast, self-financing aggregators must rely on
commercial bank funding at prevailing market interest rates, which remain
elevated. This results in a systemic financial asymmetry, rendering
many private aggregators commercially unviable and effectively excluding them
from active participation.
Members of IEAG report that GoldBod-backed aggregators
increasingly operate as direct market competitors rather than as coordinators,
often sourcing gold independently instead of aggregating through licensed
private exporters.
Another critical concern
relates to extended due diligence timelines for offtaker approval. Licensed
self-financing aggregators report waiting several months for export clearance
despite meeting statutory, compliance, and traceability
requirements.
From a regulatory
governance perspective, open-ended and discretionary approval processes
introduce uncertainty, elevate transaction risk, and undermine contract
enforceability. In international commodity markets, such delays can result in
lost contracts, reputational damage, and foregone foreign exchange inflows.
Proposal for a Risk-Based Escrow and Deposit Framework
IEAG strongly recommends
the adoption of a risk-based supervisory framework, consistent with
international best practices in commodity regulation and financial oversight.
Under this framework, Offtakers assessed as presenting elevated compliance or
counterparty risk should not be arbitrarily excluded from export activity.
Instead, such offtakers should be required to deposit a prescribed collateral
amount or full transactional value into a designated escrow or settlement
account at the Bank of Ghana.
Upon satisfaction of this deposit requirement, the offtaker should be permitted to transact under enhanced monitoring conditions. This approach would achieve several objectives that includes, mitigating default and compliance risks without eliminating legitimate market participants, replacing subjective discretion with objective, ensuring that only financially capable and committed offtakers participate in exports, and finally preserving foreign exchange integrity while maintaining competitive neutrality.
Globally, such collateralization and escrow-based controls are preferred to outright exclusion, as they maintain liquidity, investor confidence, and market depth while safeguarding regulatory objectives.
IEAG is further concerned by reports that export proceeds of self-financing aggregators are retained for extended periods in Bank of Ghana or GoldBod-linked accounts before being released.
While acknowledging the
necessity of foreign exchange monitoring, prolonged retention of funds imposes
severe liquidity constraints on private operators. In capital-intensive gold
trading, delayed fund access disrupts working capital cycles, loan servicing,
and supply continuity, ultimately shrinking formal sector parTaxation and
Revenue Sustainability Risks.
IEAG also notes ongoing public concerns regarding withholding tax compliance within segments of the mining value chain. Any regulatory framework that sidelines compliant exporters while concentrating commercial activity risks narrowing the tax base and weakening long-term domestic revenue mobilization.
Lastly, the IEAG is again worried by complaints that GoldBod is strategically delaying Know Your Customer (KYC) approvals for Offtakers working with self-financing aggregators. These delays have effectively grounded the operations of many licensed aggregators, resulting in job losses, idle capital, and the inability of compliant businesses to trade.
IEAG stresses that prolonged KYC approval bottlenecks, without clear timelines or objective criteria, undermine confidence in the regulatory framework and further entrench competitive disadvantages against self-financing operators. The Association reiterates that GoldBod should focus strictly on its regulatory and supervisory mandate and refrain from direct participation in gold buying, which places it in competition with the very entities it is mandated to regulate.
IEAG’s Call to Action
In the interest of
fairness, efficiency, and sustainability, IEAG respectfully calls on GoldBod
and relevant state institutions to:
i. Clearly separate regulatory oversight from
direct commercial activity.
ii.
Adopt a risk-based, non-discretionary
approval system for offtakers and exporters.
iii.
Implement escrow or deposit-based
safeguards at the Bank of Ghana in place of exclusionary controls.
iv.
Accelerate due diligence and clearance
timelines, with defined service-level benchmarks.
v. Review export-proceeds retention practices to align with global trade finance norms.
Ghana’s gold sector is
best served by strong regulation that enables markets, not one that substitutes
for them. IEAG remains ready to engage constructively with GoldBod, the Bank of
Ghana, and government stakeholders to ensure reforms promote inclusivity,
competitiveness, and sustainable economic growth.
Ghan
Signed,
.......................
Samson
Asaki Awingobit
Executive
Secretary
Tel:
0243575046
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