Amid the calls by banking and financial consultant, Dr. Richmond Atuahene, on President John Mahama to establish a Commission of Enquiry to conduct a forensic investigation into the alleged $42 billion “Phantom Shipment” scandal, he is offering the reasons why banks in Ghana are failing in their primary gatekeeping role.
Dr. Atuahene says the saga exposes a major breakdown in Ghana’s fight against money laundering and illicit financial flows.
In his research paper titled “Rising ML/CFT Concerns: Have Ghanaian Banks Failed as Primary Gatekeepers Against Cankers?” copied to The High Street Journal, Dr. Atuahene argues that the magnitude of the scandal, where huge sums of foreign exchange were transferred out of the country for imports that never arrived, demands an urgent, independent, and forensic audit.
The Phantom Shipment Scandal
Speaking during his maiden media encounter on September 10, 2025, President Mahama revealed that between 2020 and 2025, about $42 billion left Ghana’s financial system without any corresponding imports. These so-called “phantom shipments” were transactions backed by fake shipping documents that created the illusion of trade, when in reality, no goods arrived at the ports.
According to Dr. Atuahene, the fraudulent transactions were facilitated through commercial banks, the very institutions expected to serve as the first line of defense against money laundering and terrorist financing. To him, this revelation validates that Ghanaian banks have abdicated their roles as primary gatekeepers in the fight against money laundering and terrorist financing,” he wrote.
Why Banks Are Failing as Gatekeepers
Dr. Atuahene insists that when banks fail as gatekeepers, they weaken their ability to reduce information gaps within the financial system, making it easier for illicit funds to flow undetected. Many banks and Specialized Deposit-taking Institutions (SDIs) in Ghana have struggled with outdated risk assessments, weak customer due diligence (CDD) and know-your-customer (KYC) processes, and poor identification of politically exposed persons (PEPs) or complex ownership structures.
These lapses, he says, have left them exposed to trade-based money laundering schemes like phantom shipments and other sophisticated financial crimes.
Several factors contributed to these weaknesses, including limited resources, inadequate staff training, weak internal controls, and a lack of proper governance frameworks. Many banks, especially smaller ones, failed to invest in advanced anti-money laundering (AML) systems due to budget constraints, while some prioritized profit over compliance. Outdated technology, poor data integration, and insufficient awareness among employees further undermined efforts to detect and report suspicious activities, leaving gaps that criminals could easily exploit.
Additionally, evolving criminal tactics, cross-border illicit financial flows, and inconsistent regulatory enforcement across the sub-region have compounded the challenge. The rise of fintech and digital assets has created new vulnerabilities, while weak oversight and corruption in some institutions have further eroded the fight against money laundering and terrorist financing.
Together, these factors have reduced the effectiveness of Ghana’s banking sector as a frontline defense against financial crime.
Billions in Lost Revenue
Citing a report by the Business and Financial Times (B&FT), Dr. Atuahene revealed that Ghana lost over GHS 22.6 billion in tax revenue between April 2020 and August 2025 due to under-declared imports and unverified foreign exchange transfers tied to Import Declaration Forms.
These losses, he warned, reflect the deep-rooted economic cost of regulatory negligence and financial indiscipline.
The massive illicit flows have drained foreign reserves, worsened cedi depreciation, and pushed inflation higher. He further emphasized that this isn’t just a financial crime, it’s an economic threat.”
Call for a Forensic Audit
Dr. Atuahene maintains that the $42 billion phantom shipment is not an issue that should be treated with kid gloves. He is therefore urging President Mahama, in consultation with the Finance Minister and the Bank of Ghana, to establish a high-powered Commission of Enquiry to conduct forensic audits into both the $42 billion phantom shipment transactions and the related GHS 22.6 billion revenue loss.
The Commission, he said, should make concrete recommendations to help recover lost funds, strengthen regulatory oversight, and rebuild confidence in the financial system.
This enquiry, he says, should not be just about the culprits; it should also be about restoring the integrity of Ghana’s banking system and ensuring that our financial institutions once again become strong, trustworthy gatekeepers, and not conduits for illicit flows.
“His Excellency President John Mahama in consultation with Minister of Finance and Bank of Ghana to appoint Commission of Enquiry to conduct forensic audits in the US$ 42 billion Phantom Shipment and BFT GHS22.6 which led to the loss of revenue to the state through the Phantom imports over past five years and to make appropriate recommendations to the state and the regulator,” he noted as part of recommendations.
Dr. Atuahene’s call, he believes, if swiftly implemented, could mark the beginning of one of Ghana’s most sweeping financial investigations.
