Trade-based money laundering (TBML) has become one of Ghana’s biggest financial threats, draining billions, weakening the cedi, starving the state of revenue, and exposing gaping cracks in the country’s banking and customs systems.
Now, financial and banking consultant Dr. Richmond Atuahene has laid out an action plan to stop the financial haemorrhage.
His proposals, drawn from years of experience, research, and recent revelations of “phantom shipments” worth over US$42 billion, push for a mix of accountability, technology, training, and structural reforms across Ghana’s financial and trade ecosystem.
Below is a practical breakdown of the plan he wants the government to adopt and implement to curb the menace.
1. A National Inquiry to Expose the Rot
Dr. Atuahene wants the government to set up a Commission of Enquiry to investigate the US$42 billion phantom shipment scandal and other suspicious trade flows flagged in the B&FT’s November 2025 exposé.
The Commission would conduct a forensic audit, identify culprits, and recommend tough sanctions, taking inspiration from the UK’s £5.8 million fine against Ghana International Bank in 2022 for weak anti-money laundering controls.
2. Tougher Identity Verification and Customer Checks
According to him, banks must overhaul how they vet clients by strengthening their;
KYC (Know Your Customer)
KYCB (Know Your Customer’s Business)
CDD (Customer Due Diligence)
EDD (Enhanced Due Diligence) for high-risk cases
He insists that the Ghana Card must become the anchor ID for all verification processes.
3. Stronger Internal Controls and Independent Audits
Banks must put in place tighter internal systems to check customer activity, screen names against sanctions lists, and report suspicious behaviour to the Financial Intelligence Centre (FIC) without delay. Regular independent audits must be mandatory.
4. Automated Transaction Monitoring – Not Manual Guesswork
All 23 authorized dealer banks should deploy automated monitoring systems that use data analytics to flag suspicious trade patterns instead of relying on manual reviews.
5. AI Must Become a Central Watchdog
Dr. Atuahene calls for strong integration of AI and machine learning to spot anomalies in trade documents, detect mis-invoicing, score risk levels automatically, and track unusual patterns instantly. This would replace the outdated rule-based systems that criminals easily outsmart.
6. Blockchain + AI: A New Layer of Transparency
He proposes blending blockchain and AI cloud systems to create tamper-proof digital records of trade transactions. This would make falsifying invoices and forging shipment information far more difficult.
7. Automated STR and CTR Reporting
Suspicious Transaction Reports (STRs) and Cash Transaction Reports (CTRs) must be filed automatically using analytics and blockchain-based transaction tracking.
8. Adopt a Risk-Based Approach
Banks should allocate resources to where the danger is highest, especially in international trade finance, rather than treating all transactions equally.
9. Intense Staff Training on TBML
Bank workers and staff of financial institutions must undergo regular training on trade practices, TBML red flags, emerging criminal techniques, and AML/CFT regulations. This is essential because criminals are now more technologically savvy.
10. Strengthen Customs’ Frontline Defenses
Customs officers at borders, ports, and airports need firm enforcement powers, more patrols and inspections, modern surveillance tools, and stronger border protection
They are the country’s first line of defense against misinvoicing and trade fraud.
11. GRA Must Adopt AI and Digital Trade Tools
Dr. Atuahene says the GRA must roll out AI-based systems, cargo manifest analysis tools, e-invoicing, and digital auction platforms. These reduce human interference and curb corruption.
12. Better Surveillance and Smarter Intelligence Work
His plan further calls for more scanning technology, extended inspection hours, data-driven intelligence gathering, proactive investigations targeting suspicious networks, and smuggling, under-declaration, and fraudulent paperwork must be caught earlier.
13. Prosecute Offenders – Consistently
GRA must step up arrests and prosecutions under Act 891, working closely with Bank of Ghana, EOCO, FIC, CID, and the Military. Strong enforcement would set a deterrent tone.
14. Strengthen Information Sharing Across Institutions
Dr. Atuahene says Ghana must break the silo system. Banks, GRA, FIC, EOCO, and BoG must share intelligence seamlessly to close loopholes that TBML thrives on.
15. Continuous Capacity Building for Customs Staff
Ongoing training needs to focus on new TBML tricks, technology tools, trade procedures, and high-risk commodities. This keeps officers ahead of criminals.
16. Closer Collaboration Between Banks and GRA
The two institutions must share data to identify irregularities between trade flows and cash movements, a core weakness exposed in the phantom shipment scandal.
17. Strengthen Customs Integrity
The plan also calls for ethics training, protection for whistleblowers, sanctions for corrupt officers, an independent oversight unit, and stronger public transparency
Public trust, he argues, is essential to cleaning up the system.
18. Re-Introducing Destination Inspection
Finally, he recommends re-appointing a Destination Inspection Company to inspect goods upon arrival to verify quality, confirm correct values, ensure proper customs classification, prevent smuggling, and under-invoicing.
This would further close the loopholes that criminals exploit.
A Roadmap to Save Billions
Dr. Atuahene’s 18-point plan not only addresses TBML, it tackles weaknesses across banking, customs, enforcement, technology, and institutional discipline.
If implemented, analysts say Ghana could save billions in lost taxes, protect the cedi, restore integrity to trade systems, and safeguard national revenue.
