Highlights Of Exposed Fiscal Leakages and Governance Failures Of the Gold-for-Oil Programme

A confidential international forensic risk assessment of Ghana’s Gold-for-Oil (G4O) programme has revealed profound fiscal leakages and governance failures.

The multinational forensic review was drawn from data from the National Petroleum Authority (NPA), Bulk Oil Storage and Transportation Company (BOST), and the Customs Division.

The review identified a consistent pattern of opacity, preferential access, and structural loopholes.

Key Findings from the Forensic Review:
1. Governance Collapse in Gold Barter:
The gold leg of the programme operated without foundational contracts between the Bank of Ghana (BoG) and the Precious Minerals Marketing Company (PMMC).
This lack of governance enabled:
* Weak Pricing Controls: Inconsistent application of LBMA pricing and a lack of independent assay oversight risked undervaluation of Ghana’s gold.

* Discretionary FX Practices: The Bank of Ghana applied discretionary exchange rates, creating opportunities for arbitrage and hidden value transfers.

* Market Distortion: Mandatory gold delivery quotas created incentives for smuggling and quality manipulation, diverting true value away from the state.

A Deliberate Architecture of Obfuscation
The assessment concludes that these are not mere administrative lapses but the product of a deliberate architecture of obfuscation designed to frustrate oversight, conceal leakage, and undermine accountability.

A supplementary investigative brief highlights specific, serious concerns regarding the conduct of former BOST officials and an allied company, suggesting they were central architects of a scheme that exploited the G4O programme.

Evidence points to undisclosed offshore assets, potential trade-based money laundering, and breaches of fiduciary duties.

2. Systemic Revenue Leakage in Fuel Imports:
The analysis found that while approximately GHS 7.5 billion in import tax exemptions were lawfully granted, the absence of transparent reconciliation downstream has left the state exposed to revenue losses estimated at GHS 7.2 billion. Critical anomalies include:

* Missing Documentation: Cargoes were imported without corresponding BOST receipts, and products were received at national depots without subsequent customs declarations.

* Unchecked Exemptions: Lawful exemptions at the import stage, without downstream tracking, effectively turned deferred tax liabilities into permanent fiscal losses.

* BOST’s Dominant Role: BOST’s control over G4O cargoes amplified systemic risk and created opportunities for diversion outside the official tax net.

3. High-Risk Corporate Actors:
All international suppliers selected for the G4O programme were found to have serious due diligence concerns. These companies exhibit opaque ownership structures and have been flagged in international reports for connections to sanction-sensitive trading flows and money-laundering networks in high-risk jurisdictions like Dubai, Cyprus, and Switzerland.

Source: IMANI Africa

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