1. Background

The Chamber of Licensed Gold Buyers (CLGB), representing tiered licensed gold buyers operating under Ghana Gold Board's (GoldBod) aggregation model, acknowledges reports by the International Monetary Fund (IMF) regarding provisional losses of approximately US$214 million under the Gold-for-Reserves (G4R) program as of September 2025.

In its Fifth Review of Ghana's Extended Credit Facility (ECF) program (published mid-December 2025), the IMF noted that the Bank of Ghana (BoG) had reported losses of about US$214 million through September 2025 under the Gold-for-Reserves (G4R) program. These losses were attributed mainly to trading shortfalls in artisanal and small-scale mining (ASM) gold transactions and fees tied to GoldBod operations.

The IMF flagged the scale and rapid expansion of the G4R program - especially after the creation of GoldBod.

The concern centers on how operational costs, pricing gaps, and off-taker discounts could weaken the central bank's balance sheet and external position if not managed carefully.

Loss Figures Refer to the Bank of Ghana, Not GoldBod Directly. According to the report of the IMF staff assessment, the US$214 million figure relates to the overall loss recorded by the BoG under Gold-for- Reserves. GoldBod itself was not named as an entity making the loss; rather, IMF text points to off-taker fees and trading shortfalls involving ASM dore transactions connected to the program.

What This Means (Implications)

Different Accounting Perspectives: The IMF uses its own staff analysis and early internal figures (usually provisional) to assess program performance, while Ghanaian institutions emphasize formal audited financial accounts, which may not yet be available.

Macro Risk Focus: The IMF is not solely focused on whether a public entity (like GoldBod) posted a profit or loss, but on the potential risk large commodity-backed programs pose to the central bank's balance sheet and fiscal position if pricing or execution are weak.

Governance and Transparency: As with other IMF country programs, the Fund emphasizes transparency, risk management, proper pricing, and clear financial reporting when state agencies engage in large commercial transactions — especially in volatile commodities like gold.

The CLGB recognizes the IMF's emphasis on the potential macroeconomic and operational risks associated with the rapid scaling of gold aggregation and reserve management activities. At the same time, CLGB seeks to provide contextual clarity from the perspective of licensed gold buyers, whose operations form the backbone of the formal ASM gold supply chain.

"Gold sector reforms must be anchored not only in national interest, but also in sound commercial design and risk management," said Kwaku Amoah, CEO of the Chamber of Licensed Gold Buyers. "Strengthening GoldBod's operational architecture—particularly pricing transparency, settlement efficiency, and private sector participation—will be critical to preventing future balance sheet pressures."

CLGB recognizes the importance of restoring balance sheet strength at the Bank of Ghana as part of Ghana's broader macroeconomic recovery efforts. The Chamber notes that while the policy objective of retaining gold value domestically and supporting foreign exchange inflows remains sound, execution challenges within the current gold aggregation and trading framework may have exposed operational gaps that require urgent attention.

2. Perspective of Licensed Gold Buyers under the GoldBod Aggregation Model

1. Facilitation Role of Licensed Buyers

Licensed gold buyers act as intermediaries, sourcing gold from artisanal and small-scale miners (ASM) and channeling it into the formal aggregation framework managed by GoldBod. These buyers operate within a structured regulatory and pricing environment, ensuring compliance, traceability, and formalisation of the ASM sector.

2. Separation of Operational and Balance-Sheet Outcomes

CLGB notes that the IMF-reported losses are reflected on the Bank of Ghana's balance sheet under the G4R program. These losses primarily relate to timing gaps, international gold price volatility, and transaction execution. Licensed gold buyers do not directly incur or record these losses, as they are remunerated via regulated buyer margins and fees for their aggregation and compliance services.

3. Operational Challenges

Licensed buyers face challenges such as:

o ASM gold quality variations affecting valuation.

o Logistics and compliance costs under formalisation mandates.

o Volatility in international gold prices impacting the timing of sales into the G4R program.

These operational challenges underscore the importance of a predictable and transparent aggregation and pricing framework to support both buyers and the broader formal gold sector.

3. Recommendations Going Forward

CLGB proposes the following measures to strengthen the G4R program, mitigate perceived risks, and enhance the formal gold supply chain:

1. Transparent Accounting and Reporting

o Align reporting of gold program outcomes between BoG, GoldBod, and licensed buyers.

o Introduce quarterly reconciliations to clarify operational costs, fees, and margins.

2. Enhanced Pricing Mechanism

o Adopt standardized pricing formulas reflecting LBMA benchmarks, ASM grade adjustments, and agreed aggregation margins.

o Minimise timing mismatches between acquisition and reserve recognition.

3. Risk-Sharing and Operational Clarity

o Clearly define which entity (BoG, GoldBod, or buyers) bears specific market and operational risks.

o Consider introducing hedging or forward-sale mechanisms to reduce exposure to international price fluctuations.

o Ensure commercial activities are insulated from monetary policy balance sheet exposure.

o GoldBod operate as a commercially viable, self-financing entity without creating fiscal or FX risks.

o GoldBod departs from this model by entering direct buying and trading, which automatically raises IMF red flags and maintain zero reliance on BoG financing.

4. Capacity Building for Licensed Buyers

o Provide training and technical support to enhance assaying, valuation, market pricing and compliance capabilities.

o Incentivize formalization and quality improvement through structured buyer participation.

5. Strategic Communication with IMF and Stakeholders

o Present a fact-based distinction between BoG balance-sheet provisional outcomes and operational performance of GoldBod and licensed buyers.

o Highlight the long-term benefits of ASM formalisation, FX reserve accumulation, and market transparency in Ghana's gold sector.

4. Conclusion

The CLGB re-affirms its commitment to supporting the formalization of Ghana's ASM sector under GoldBod's aggregation model that promote market stability and sustainable value retention for Ghana. While the IMF's concerns highlight macroeconomic vigilance, licensed gold buyers remain critical partners in operationalising the G4R program. With transparent reporting, risk clarity, and effective pricing mechanisms, the sector can deliver sustainable reserve accumulation, formal sector growth, and economic benefits for Ghana.

Signed.

All Media Houses.