Ghana’s evolving gold trading regime will ultimately be judged not by official assurances but by the quality and depth of information placed in the public domain, a Ghanaian transactional expert and lawyer, Amanda Akuokor Clinton, has said.

Ms Clinton, Head of Chambers at Clinton Consultancy, said, “Credibility will ultimately be measured through disclosure rather than rhetoric," stressing that transparency must extend beyond institutional statements to the financial and commercial transactions underpinning the operations of the Ghana Gold Board (GoldBod).

She made the observation in an interview with Critical Frontiers on Tuesday, August 25, in which she examined the emerging formal gold market and the governance, investment and commercial issues surrounding GoldBod.

Disclosure as the test

Ms Clinton said GoldBod’s credibility would increasingly depend on whether stakeholders could independently examine the figures and transactions underpinning its operations.

She identified the publication of audited financial statements as one of the fundamental tests, alongside reconciliation of gold purchases with export volumes and transparent accounting for trading costs.

She also called for disclosure of material discounts, spreads and fees, clearly stated licensing requirements, traceability of gold flows and greater procurement transparency.

According to her, GoldBod should also provide greater clarity on transactions involving off-takers and its commercial exposures, while ensuring that gold moving through the formal system can be independently reconciled and audited.

She acknowledged that GoldBod had been publishing information on licensing criteria but said the bigger transparency question concerned the institution’s commercial and financial activities.

Investor confidence

Ms Clinton's comments come amid wider discussions about the structure and credibility of Ghana's formalised gold trading system, particularly as GoldBod assumes a more prominent role in the purchase and aggregation of artisanal and small-scale mining (ASM) gold.

She noted concerns raised by institutional investors who, according to the issues discussed during the interview, allegedly committed substantial funds without receiving contracted gold within expected transaction cycles.

There were also concerns about the treatment of foreign-currency inflows and their conversion into Ghanaian cedis, with some clients reportedly questioning discrepancies between expected and realised values.

Ms Clinton's comments did not establish the allegations as fact, but used them to illustrate the importance of stronger disclosure and independently verifiable transaction records.

Regulator and market participant

A key issue identified in the discussion is GoldBod’s unusual position within the market.

The institution operates as a regulator and market gatekeeper while also participating directly in gold purchasing and aggregation.

That combination, Ms Clinton suggested, makes transparency, auditability and independent oversight particularly important to maintaining confidence among miners, aggregators, investors and other market participants.

The situation also places a premium on clear rules governing foreign exchange, transaction reconciliation, delivery obligations, dispute resolution and commercial exposures.

Formalisation must offer value

Ms Clinton further pointed to the continued strength of Ghana’s informal gold economy, where miners and aggregators have access to international price information and are capable of assessing margins and commercial alternatives.

Consequently, she said, the sustainability of Ghana’s formalisation agenda would depend not merely on bringing operators into a regulated system but on making that system commercially attractive.

The long-term measure of success, therefore, would be whether formalisation offers miners, aggregators and international investors a more predictable, transparent and competitive environment than informal channels.