Ghana is currently experiencing a situation where billions of dollars are quietly slipping through the nation’s international trade system. These are billions of dollars that never show up in imports, duties, or the foreign-exchange ledgers the state relies on.
This is not a figment of anyone’s imagination, it’s what recent investigations and expert analysis suggest has been happening in Ghana. There is a massive volume of trade-based money laundering (TBML), and indications that both the Customs arm of the Ghana Revenue Authority (GRA) and commercial banks, the country’s two primary gatekeepers, may not be helping matters, in addition to other factors.
Amid the situation, Dr. Richmond Atuahene, a banking and financial consultant, in an extensive research has painted a worrying picture of the situation. The situation involves what the expert calls phantom shipments, falsified invoices, under- and over-invoicing, multiple uses of single import forms, and suspicious foreign transfers.
The headline figures are staggering as estimates range into the tens of billions of dollars over recent years, and the human and fiscal consequences are immediate, such as lost revenue, weaker reserves, a weaker cedi, and higher inflation.
What exactly is TBML — and why is it so Hard to catch?
According to Dr. Atuahene, trade-based money laundering (TBML) works by hiding illicit money in ordinary trade transactions. In some instances, a shipment is over-invoiced so extra money can be siphoned abroad; a consignment is declared as low-value but sold at market rates elsewhere; or “phantom shipments” are recorded on paper but never physically move.
These schemes, he says, exploit complex supply chains, multiple intermediaries, and cross-border jurisdictions, and rely heavily on weak verification systems and poor data links between institutions.
Unlike a simple suspicious bank transfer, TBML lives in a forest of documents such as invoices, bills of lading, certificates of origin, and import declaration forms (IDFs). Detecting anomalies requires cross-checking trade data against payments and shipment records, something that is difficult if data is fragmented, manual, or siloed.
Banks: The Gatekeepers That Sometimes Look the Other Way
The financial expert says commercial banks are supposed to be the first line of defence against illicit flows. Yet the data shows troubling patterns. Between April 2020 and August 2025, banks alone facilitated roughly US$20 billion in foreign transfers that couldn’t be matched with imports, according to investigative analyses. “This resulted in an estimated revenue loss of over GH¢22.6 billion from unpaid duties and taxes,” Dr. Atuahene indicated.
In addition, less than 2% of those transfers were linked to actual imports, suggesting massive gaps in due diligence. Multiple transfers for the same client, repeated use of single IDFs, and absence of supporting trade documents were common red flags that often went unchallenged.
The question on the minds of many now is: Why did this happen? Dr. Atuahene points to several causes. These include weak AML controls, insufficient specialist expertise in trade finance, under-resourced compliance units, poor technology, and a culture that sometimes prioritised business growth over rigorous checks.
In short, the checks were there on paper, but enforcement and scrutiny were insufficient in practice.
Customs: Another Gatekeeper with Serious Challenges
Dr. Atuahene further notes that the GRA Customs Division has a dual mandate, which is to collect revenue and facilitate trade. Their role is also very crucial in the combat of illicit financial flows, including TBML.
“Customs services play a critical global role as ‘gatekeepers’ by acting as the primary line of defence at international borders, strategically positioned to identify, intercept, and disrupt the physical flow of illicit goods and associated funds involved in trade-based money laundering (TBML),” Dr. Atuahene maintains.
That balancing act is not unique to Ghana, but the division’s performance has been hampered by a number of factors that are fuelling TBML.
Data fragmentation: Trade data is scattered across agencies and private actors, with limited ability to match payments, shipments, and customs declarations.
Manual systems and legacy processes: Heavy reliance on paperwork and human checks that are vulnerable to falsification.
Capacity gaps: Limited staff training on TBML typologies, commodity price benchmarks, and complex cross-border schemes.
Corruption risks: Reports and studies indicate that bribery and collusion have opened doors for under-declaration and misclassification.
High volume & low resource: Ports are busy. Thorough checks are time-consuming; officials face pressure to clear cargo quickly to keep trade moving.
These and many other factors result in mis-declared cargo, phantom shipments, and large discrepancies in reported exports (for example, gaps in gold trade statistics with the UAE) that point to sizeable revenue leakages.
The Damage: Revenue, Reserves, and the Everyday Impact
The financial analyst continues that the consequences of unchecked TBML are not abstract. The impact on the government and the citizens alike.
Lost revenues: Duty and tax shortfalls, estimated in the billions, mean less money for roads, schools, health, and social services.
Reserve erosion & currency pressure: Large illicit outflows reduce FX buffers and put downward pressure on the cedi, raising import costs and fuelling inflation.
Market distortion: Legitimate exporters and importers face unfair competition from actors using illicit routes to lower costs.
Reputational risk: Frequent AML failings attract international scrutiny, possible sanctions, and higher compliance costs for banks operating cross-border.
For him, President John Mahama’s recent statement that phantom shipments of around US$42 billion had been conducted via the main gatekeepers, which grabbed headlines, if accurate, underlines the scale of the crisis.
Root Causes
The problem is not a single failure but a system failure. Key weaknesses, he says, include the following;
Technology gaps: Lack of advanced analytics, AI, or integrated trade-finance platforms to spot anomalies across huge datasets.
Information silos: Customs, banks, the Financial Intelligence Centre (FIC), shipping firms, and tax authorities operate with limited real-time data sharing.
Skills shortage: Investigating TBML requires cross-disciplinary expertise in trade, commodities, and financial crime, which is in short supply.
Weak oversight and accountability: Regulatory enforcement and penalties have been inconsistent, diluting deterrence.
Perverse incentives: High revenue targets, pressure to expedite clearances, and profit motives in banks can all blunt rigorous controls.
A National Test
TBML is not merely a technical compliance problem; it is a test of state capacity. He believes that stopping it will require political will, sustained investment in technology and skills, and a shift in institutional incentives away from short-term convenience toward long-term public interest.
If Ghana can tighten its gatekeeping, integrate data, empower investigators, and hold institutions accountable, it can stop the haemorrhage of revenue and restore trust in the systems that underpin the economy.
If not, the costs will continue to hit the public purse and ordinary households in the form of higher prices and fewer public services.
