1. Preamble

The Ghana Chamber of Mines (“the Chamber”) acknowledges the mandate of the Ghana Gold Board (“GoldBod”) in strengthening Ghana’s mineral export revenue framework and commends its efforts to improve export revenue flows from the artisanal and small-scale mining sector to the Bank of Ghana. The Chamber remains fully supportive of the GoldBod’s role in the industry.

However, the Chamber is compelled to formally respond to a widely publicised statistic attributed to the Chief Executive Officer of the Gold Board at the ceremony commemorating the sale of Damang Gold Mine’s first output to the Bank of Ghana through the Gold Board. It was alleged that export proceeds repatriated by the large-scale mining segment do not exceed 20 per cent of total mineral export proceeds. The Chamber respectfully submits that this figure is materially misleading.

The cited statistic is derived solely from bullion gold and foreign exchange sold directly to the Bank of Ghana. This approach captures only one channel of forex repatriation and excludes substantial inflows through the commercial banking system. Consequently, it significantly understates the large-scale sector’s contribution to Ghana’s foreign exchange position.

2. Channels of Forex Repatriation

Large-scale mining companies repatriate export proceeds through two established channels:

• Direct sales of forex and bullion gold to the Bank of Ghana (central bank channel); and
• Repatriation through commercial banks domiciled in Ghana (commercial bank channel).

A comprehensive and technically sound assessment of mineral export proceeds must incorporate both channels. The 20 per cent figure reflects only transactions with the Bank of Ghana and is therefore incomplete.

3. Role of the Commercial Banking Channel

Large-scale mining companies maintain accounts with commercial banks in Ghana through which a significant portion of export proceeds is repatriated and utilised to meet domestic obligations.

These include the settlement of foreign-currency-denominated liabilities within Ghana, notably:

• Payment of royalties to the Government of Ghana, typically denominated in United States dollars;
• Payments for domestically provided services such as electricity and fuel, which are invoiced in foreign currency but received by Ghanaian institutions based on a dispensation from the Bank of Ghana.

In addition, a portion of forex proceeds repatriated through commercial banks are converted into Ghana cedis to meet local obligations, including employee remuneration, corporate social investment projects in host mining communities, payments to government agencies and in-country vendors. These conversions directly augment the domestic foreign exchange supply and support exchange rate stability.

Based on industry data, approximately 70 per cent of mineral export proceeds from the Chamber’s producing members is returned to Ghana through a combination of the central bank and commercial banking channels to support these obligations.

4. Measurement of Forex Contribution

The Chamber emphasises the distinction between gross forex repatriation, the total foreign exchange returned to Ghana, and net forex retention, which reflects the portion remaining after external obligations are settled.

The appropriate metric for assessing the mining sector’s contribution to Ghana’s foreign exchange position is gross repatriation, consistent with balance-of-payments accounting principles.

The 20 per cent figure does not meet this standard, as it excludes the commercial banking channel entirely. A complete accounting that includes both channels would yield a materially higher estimate of forex inflows attributable to the large-scale mining sector.

5. Policy Context

Until recently, the Bank of Ghana maintained a policy requiring mining companies to grant it a right of first refusal on foreign exchange intended for sale to commercial banks. This policy underscores the recognised role of the commercial banking channel in forex repatriation.

Accordingly, the data required to produce a comprehensive account of forex inflows from the mining sector should be available to the Bank of Ghana. The Chamber therefore encourages the publication of a disaggregated and transparent account of mineral sector forex flows across both channels to support informed public discourse.

6. Conclusion

The Chamber respectfully urges stakeholders to adopt a comprehensive and data-driven approach to evaluating mineral export proceeds. Accurate measurement of forex flows is essential for sound policymaking, macroeconomic management, and sustaining confidence in Ghana’s mining sector.