You can have a million anti-corruption laws on Ghana’s statute books and even set up an Office of Special Prosecutor, but if a person can walk to a bank and withdraw ¢21 million in hard cash from his company’s bank account and distribute same in the name of business promotion without any trail of who received the money, then you must be joking if you think we are fighting corruption in Ghana! Once the Management and Board of Directors of the said company are in sync, there is little any auditor or anybody else can do about the disbursement of the ¢21 million in hard cash!

Limit Cash Withdrawal from Banks and MoMo Wallets to ¢3,000

What if Parliament passes a law that limits the amount of cash one can withdraw from a bank or any financial institution (including Mobile Money Wallet) to ¢3,000? Yes, I propose we pass a law that limits the amount of cash that any individual or corporate institution can withdraw over the counter from a bank to ¢3,000. Further, any electronic payment made by a corporate institution (private or public) to an individual or a company above ¢3,000 must have a record via a ‘Networth Aggregator’ portal to be hosted by the Ghana Revenue Authority (I will discuss Networth Aggregator later).

Using the hypothetical example I cited in the first paragraph, it would take 7,000 withdrawals from the bank to mobilize GHS21 million in hard CASH to undertake business promotion without audit trail if Parliament passed a law to limit cash withdrawal to ¢3,000. But why is a limit to cash withdrawal critical to the fight against corruption in Ghana? Take a typical government contract, for example.

Let’s say a Government institution undertakes a project and awards the contract to Contractor ‘A’ under sole-sourcing or restricted tendering method, with approval from the Public Procurement Authority. Let’s say government officials up and down the chain collude with Contractor ‘A’ to inflate the contract price. When Contractor ‘A’ finally gets paid, he is not going to transfer the corrupt money (that he received through the inflated contract price) to the government officials through their bank accounts. He would go to the bank, withdraw millions of Cedis or Dollars, carry the money in jute bags and distribute the CASH to these government officials! That is classic big-time corruption, though there are many other means by which Ghana loses money through corruption.

So, what if by law Contractor ‘A’ can only withdraw maximum ¢3,000 from his bank account at any one time? And what if Contractor ‘A’ can also not make any electronic payments exceeding ¢3,000 without quoting the Ghana Card number (if the recipient is an individual) or the Tax Identification Number (if the recipient is a corporate institution)? What if all these electronic payments must reflect on the Networth Aggregator portal hosted by the Ghana Revenue Authority (GRA)?  

What is Networth Aggregator?

I am proposing the amendment of our income tax law to set up a database and online portal using each individual citizen’s Ghana Card number and each company’s Tax Identification Number (TIN) as unique identifiers. Each individual or company would have an electromic ledger or account. Whenever a person or company receives any income or asset above the GHS3,000 threshold, their Ghana Card number or TIN must be used to record the amount and description on the GRA Networth Aggregator ledger or account for that individual or company.

So, let’s say I receive ¢10,000 from Contractor ‘A’ for business promotion. The contractor would be expected to go the GRA portal, enter my Ghana Card number to pull out my basic details with fields to enter the payment and description as business promotion. Immediately, my Networth Aggregator accounts at GRA records that I have received ¢10,000. If I go to the lands commission to register a piece of land worth GHS100,000, somebody would be expected to record that transaction on my GRA Networth Aggregator account.

If I register a new Mercedes at DVLA, an official there would record the ¢500,000 value on my GRA Networth Aggregator account. If I want a building permit from my Municipal Assembly, the quantity surveyor would have done the bill of quantities and somebody will estimate the value of the building when completed and add the value to my GRA Networth Aggregator account. I’m sure you catch my drift with the GRA Networth Aggregator concept, don’t you? Now, if I am a civil servant whose official take-home income is say ¢100,000 per year, my GRA Networth Aggregator account will provide electronic evidence that I am earning far in excess of the official income unless I can prove that I have another source of income.

Two things could happen: GRA’s primary interest is to chase me for income tax at the end of the financial year, thereby broadening the tax net. But most importantly, will I or Contractor ‘A’ take the risk of receiving payment of corrupt money, when there would be an electronic audit trail of the payment via my GRA Networth Aggregator account? And oh, if you think a company can make thousands of ¢3,000 payments to one person over time, think again. It takes a simple algorithm to raise RED FLAGS of a pattern of flow or repeat transfers between one company and the same sets of recipients.

So, do we as a country seriously want to fight corruption? Then let’s limit the amount of cash one can legally withdraw from their bank account or mobile money wallet. With Universal QR Code now in operation in Ghana, mobile money interoperability and many electronic bank products available, we have practically no excuse in not limiting cash transactions. This will even have unintended benefits of reducing armed robbery attacks as well as save the Bank of Ghana some cost of printing cash. The overriding view though is, corruption thrives when money can be paid in cash without (electronic) audit trail. Limiting cash withdrawals coupled with the proposed GRA Networth Aggregator are just two measures that can have immediate impact on the fight against corruption in Ghana.

And yes, even political parties may benefit from doing more electronic instead of cash transactions. How many acrimonious internal fights did the media report on in the just-ended elections as a result of monies allegedly not reaching the people at the local level, leading to apathy among party footsoldiers? Or is it that the political parties endorse corruption because that may be how they mobilise campaign funds? Why can’t genuine party financiers donate legitimately to political parties in a transparent manner through various legal avenues, like Political Action Committees that they have in the United States?

And to those who might be asking questions about privacy, please understand that by existing income tax laws, you are expected to file your tax returns with GRA every year. This means you are currently required by law to disclose all your income to the GRA. What is being proposed would make it difficult for people to hide corrupt and other illicit income in cash and other movable and immovable properties.