Ghana’s efforts to formalise its gold market will require stronger transparency and oversight as the Ghana Gold Board (GoldBod) assumes a broader role in regulating and participating in the industry, transactional expert Amanda Akuokor Clinton has said.
Clinton made the observation during an interview focused on Ghana’s gold market, investor exposure, foreign-exchange conversion, formalisation and the institutional risks emerging from the growing concentration of market functions within GoldBod.
The concern is less about the strength of GoldBod’s authority than about whether investors and other market participants can predict how the institution operates, understand the economics of transactions and seek independent redress when disputes arise.
GoldBod now sits at the centre of Ghana’s formal gold-market architecture, with responsibilities covering licensing, gold purchasing, aggregation, assaying, valuation and exports.
That combination of regulatory and commercial functions, Clinton argued, makes transparency increasingly important.
She described GoldBod as effectively both a “referee” and a market participant, noting that investors can operate comfortably under a powerful regulator when the rules are clear and decisions are predictable.
“Investors are not afraid of a powerful regulator; they are afraid of an unpredictable regulator,” Clinton said.
Transparency and the investor question
The issue, therefore, extends beyond regulation to what investors can actually see when they put money into Ghana’s gold market.
Clinton pointed to audited financial statements, reconciliation between gold purchases and exports, disclosure of trading costs, discounts and spreads, traceability of gold flows and greater clarity around transactions with off-takers as important measures of institutional credibility.
“Credibility will ultimately be measured through disclosure rather than rhetoric,” she said.
The argument comes as GoldBod takes on greater responsibility for the commercial side of the market, making the transparency of its pricing, financing and settlement arrangements increasingly relevant to investors.
For institutional investors, however, the exposure does not begin and end with the price of gold.
A transaction can involve financing costs, aggregation charges, banking fees, foreign-exchange conversion, compliance expenses, transportation, assay, security, refining and settlement. Even relatively small differences across those stages can affect the overall economics of a deal.
“Every basis point in the transaction architecture matters,” Clinton said.
That concern brings the foreign-exchange component of Ghana’s gold trade into focus.
FX conversion and delivery concerns
According to Clinton, some clients had raised concerns over the conversion of dollar funds into Ghanaian cedis in transactions linked to the formal gold market, including what they considered significant discrepancies between the value committed in dollars and the cedi value received after conversion.
The concern, as presented in the interview, was not simply that foreign currency was converted into cedis, but the rate applied, the timing of conversion and any spreads or charges attached to the process.
The question for investors is therefore whether the FX mechanism is sufficiently transparent to show exactly how the value of their funds is determined and where any difference in rates is captured.
Those concerns sit alongside claims of delays in the delivery of gold.
Clinton said she was aware of institutional investors that had committed millions of dollars but had encountered difficulties completing even their first or second transactions, including delays relating to gold delivery.
The claims are based on market participants’ experiences and require independent verification before being treated as established facts. But if similar problems occur across multiple transactions, the implications could extend beyond individual commercial disputes to Ghana’s wider investment reputation.
For an investor dealing with a private counterparty, a failure to perform can be pursued as a conventional commercial dispute. A dispute involving a government-linked institution that also has regulatory influence over the market presents a more complicated calculation.
That, Clinton said, could make arbitration or negotiated settlements preferable to highly public litigation in some circumstances.
Formalisation has to work commercially
The investor concerns ultimately connect to the broader objective of Ghana’s gold-market reforms: bringing more of the country’s gold into the formal and traceable system.
Clinton’s view is that regulation alone will not achieve that.
Miners and aggregators will compare the returns, speed of payment, financing conditions and administrative requirements associated with the formal market against the alternatives available to them.
“If the informal sector can get a better margin, they will continue to find other channels,” she said.
That makes the economics of formalisation just as important as its regulatory design.
GoldBod needs the informal supply network to bring sufficient volumes into the formal market, while those same miners and aggregators retain the ability to redirect supply when the commercial incentives change.
The risk, therefore, is that a system designed to eliminate informal trading could inadvertently make it more attractive if compliance costs, delays or weaker margins outweigh the benefits of operating formally.
The broader test for GoldBod
Clinton’s argument ultimately places GoldBod’s growing authority against a wider question of institutional credibility.
The success of Ghana’s formal gold-market model will not be determined only by how much gold GoldBod purchases or how effectively it regulates market participants.
It will also depend on whether investors can understand the cost of transactions, whether gold and financial flows can be reconciled, whether disputes can be resolved without creating additional commercial risks and whether miners and aggregators find the formal market competitive enough to remain within it.
The greater the concentration of functions within GoldBod, Clinton argued, the greater the need for transparent and auditable systems around those functions.
For Ghana, the challenge is therefore moving beyond formalisation by authority towards a market that earns confidence through predictability, disclosure and commercially viable transactions.
