OPINION: GOLDBOD and its order to gold buyers – and why it may not wash (part I)

Dear Sammy Gyamfi: your press statement dated 18 August 2025, in which you sought to demand that all gold buyers licensed in Ghana issue GOLDBOD receipts for all purchases, seems a move to keep the industry’s administrative business in order. No one would fault you for wanting to do that.However, please take note of the following:

In a fair gold market, where price is freely determined by market dynamics, GOLDBOD may not need to issue this basic administrative directive.

What your press release signals is that there is a threat against the operations of GOLDBOD: hence the unleashing of a task force and inspectors.

Questions of origin

Let us look at the possible reasons for your directive.

1. Could the move be just administrative? But if so, why now – after months of operations? OK, maybe it’s a reminder.
2. Could it be that GOLDBOD has seen a drop in trade volumes over a short period and suspects something fishy is going on, even amongst its own aggregators … and maybe it can’t tell Ghanaians right now?
3. It could be that it is a move by your institution to appear to international bodies and frameworks that you are compliant with the OECD’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas – even though you don’t know where some of your product comes from. Traceability, per the OECD, enjoins that you should be able to trace every ounce of gold to the mine of origin and not “GOLD SHOP OF ORIGIN”. Previous governments in Ghana have not achieved this and did not create an impression that receipting of gold purchases meant traceability as peddled.
4. It could also be that GOLDBOD is faced with tussles over price or mistrust among its own appointed aggregators and, possibly, it may suspect that they are undertaking dealings with state funds behind the Gold Board framework.
5. It could also be that GOLDBOD wants to track who sells what to which aggregator, and where does that aggregator take that product to – maybe not to GOLDBOD?
6. Aggregators financed by the state may, in some cases, divert gold purchased using state funds, sell to a higher bidder than GOLDBOD, make between 10% and 20%, and repeat the cycle two or three times before delivering goods to GOLDBOD … at an even higher price than intended, if there are fluctuations in the market. This may happen with or without the support of highly placed individuals at GOLDBOD.

Strike a golden pose

My list of suspicions is endless.

Why is it possible these things are happening, and why is GOLDBOD now chasing receipts?

1. I repeat (and shall repeat again): GOLDBOD should be careful how it manipulates prices for gold, even against the backdrop of the cedi appreciating. (Look out for more on this in my next post.)
2. Though I am not contesting the exchange rate used by GOLDBOD, recent comments by the IMF/World Bank and forex payment activity suggest that the rate used may not be market-competitive.
3. Ghana is a country where, some experts estimate, over 60% of gold from the small-scale mining sector is either mined or sourced inappropriately or illegally; this gold is further proxied as legal and is then exported for foreign exchange to support the government’s economic policy. Such a country may not have the moral right to criminalise possession of gold without a permit from GOLDBOD. How can it, when that same GOLDBOD does not appear to know where its gold comes from? Think about it …
4. You can’t criminalise the hoarding of gold by individuals and be asking for receipts for transactions. The gold isn’t for you: it is those individuals’ investments. They won’t issue receipts for you to trace the gold that they hold. Think about it …
5. You can’t manipulate prices and expect that buyers and sellers won’t find common cause to cause you losses.

What GOLDBOD needs to do

1. The Gold Board must liberalise the markets while keeping a firm grip on its regulatory role. The monopoly it is seeking will cripple the institution in the long run as the smuggling cartels thrive, wooing miners with good prices.
2. GOLDBOD should pay the miners international prices as the market may dictate.
3. Decentralise GOLDBOD offices across all mining regions/districts in Ghana. Bring formalisation along with licensing and monitoring to their doorstep. Closed offices of the PMMC (Precious Minerals Marketing Company) should be reopened: there is no sense in making a miner travel from Tarkwa to Accra to seek a gold trading permit …
4. Prepare to phase off state financing of gold purchases. It may sound stupid now, but archive this. GOLDBOD and Bank of Ghana should see gold purchasing not only as a commercial activity, but as a form of reserve accumulation. Smugglers have the mindset of central banks: they buy to accumulate and wait for a boom cycle, and they will pay anything to get what they want today.

Ing Wisdom Gomashie

The writer is a mining engineer, consultant and former ministerial special assistant in the Ministry of Lands and Natural Resources

This is an edited version of an opinion piece first published on Facebook