The Importers and Exporters Association of Ghana, IEAG, is calling for a shift to a risk based regulatory framework for gold exports, warning that discretionary approval processes and prolonged compliance delays are increasing transaction risk and hurting Ghana’s position in international commodity markets.
In a policy statement, the Association said open ended and subjective approval systems for offtakers and exporters create uncertainty, weaken contract enforceability, and expose traders to potential contract losses, reputational damage, and reduced foreign exchange inflows.
IEAG is proposing an escrow and deposit backed supervision model to replace what it describes as exclusionary or discretionary controls.
Escrow Framework Proposed for High Risk Offtakers
Under the proposed framework, offtakers assessed as presenting elevated compliance or counterparty risk would not be automatically barred from export activity. Instead, they would be required to deposit collateral or the full transaction value into a designated escrow or settlement account at the Bank of Ghana before being cleared to trade.
According to IEAG, this would allow regulators to manage risk without removing legitimate participants from the market.
The Association said the approach would help reduce default risk, ensure only financially capable exporters transact, and protect foreign exchange flows, while maintaining competitive neutrality across the sector.
It added that escrow and collateral based controls are widely used in international commodity and financial markets to safeguard regulatory objectives without undermining market liquidity.
Concerns Over Export Proceeds Retention
IEAG also raised concerns about reports that export proceeds belonging to self financing aggregators are being held for extended periods in Bank of Ghana or GoldBod linked accounts before release.
While acknowledging the need for foreign exchange monitoring, the Association said prolonged retention of funds places heavy liquidity pressure on private operators in the gold trade.
It warned that delayed access to funds can disrupt working capital cycles, affect loan servicing, and interrupt supply chains, with the risk of reducing formal sector participation.
KYC Delays and Tax Risks Highlighted
The Association further cited complaints about delays in Know Your Customer approvals for offtakers working with self financing aggregators, saying the bottlenecks have grounded some licensed operators and led to idle capital and job losses.
IEAG also noted concerns about withholding tax compliance within parts of the mining value chain, cautioning that sidelining compliant exporters while concentrating activity among a smaller group of operators could narrow the tax base and weaken domestic revenue mobilisation.
Call to Separate Regulatory and Commercial Roles
IEAG is urging GoldBod and relevant state institutions to clearly separate regulatory oversight from direct commercial activity in gold buying. It argues that regulators should focus strictly on supervision and enforcement to avoid competitive conflicts within the market.
The Association called for defined approval timelines, non discretionary clearance systems, escrow based safeguards, and a review of export proceeds retention practices to align with global trade finance standards.
IEAG said it is ready to engage GoldBod, the Bank of Ghana, and government stakeholders to support reforms aimed at improving fairness, efficiency, and sustainability in Ghana’s gold export sector.