Financial Integrity Monitor

Ghana GH

Domains (D1–D6)
3
Sources
14
Role actions
8
Horizon <90d
2
Jurisdiction profile
CompliantTier BRisk: StableMixed

Ghana's AML/CFT regime rests on the Anti-Money Laundering Act 2020 (Act 1044, amending Act 749), Companies Act 2019 (Act 992) beneficial-ownership provisions, and the newly passed Virtual Asset Service Providers Act (Dec 2025) bringing crypto under Bank of Ghana/SEC supervision.

MoreThe Financial Intelligence Centre anchors the FIU function; EOCO investigates and prosecutes economic crime. Delisted from the FATF grey list in 2021, Ghana remains in GIABA's enhanced follow-up process with residual technical-compliance gaps.

Key deficiencies
  • Weak risk-based supervision of DNFBPs and non-bank financial institutions limiting STR volume and quality
  • Beneficial ownership verification gaps at the Registrar-General's Department, particularly for foreign legal persons
  • Limited prosecution of standalone/third-party money laundering offences; focus remains on predicate offences and self-laundering
  • Scale of galamsey-linked illegal gold mining and gold smuggling outpaces enforcement and traceability capacity
  • Government does not routinely publish arrest/prosecution statistics, constraining independent effectiveness assessment
Recent developments (18m)
  • GIABA 2022 Follow-Up Report re-rated Ghana on Recommendations 8, 33 and 35 while retaining enhanced follow-up status
  • Parliament passed the Virtual Asset Service Providers Bill (Dec 2025), formally bringing crypto exchanges under Bank of Ghana/SEC licensing
  • Ghana SEC named 11 companies to a 12-month virtual asset trading pilot beginning March 2026
  • OFAC designated Aleksandr Mira Serda (born Ntifo-Siaw, alternate Ghanaian nationality), a Garantex co-owner, in the August 2025 Russia-sanctions-evasion crypto action
  • INTERPOL Operation Serengeti 2.0 (Jun-Aug 2025) acted on TRM Labs leads identifying Bl00dy ransomware laundering infrastructure active in Ghana
  • Ghanaian authorities arrested three Indian nationals in April 2025 for a decade-long gold smuggling operation
  • FATF and GIABA held a Joint Experts Meeting in Accra (Nov 2025) on money laundering/TF trends and trade-based financial crime
  • UNODC published a corruption risk assessment for Ghana (March 2025) and Ghana enacted hazardous-waste/pollution legislation (Act 1124, 2025) tied to galamsey enforcement
Weekly brief

Lead signal

Lead Signal

Read full brief

Lead Signal

Ghana's Virtual Asset Service Providers Act, 2025 (Act 1154) has moved into phased implementation this cycle, and the shift is architectural rather than incidental. The Act gives the Bank of Ghana primary licensing authority over virtual-asset service providers, through a dedicated Virtual Assets Department operating alongside the Securities and Exchange Commission and the Financial Intelligence Centre, and it mandates customer due diligence, suspicious-transaction reporting to the FIC, and AML/CFT compliance aligned to FATF standards, including Travel Rule obligations. A registration deadline for existing VASPs serving Ghanaian residents passed on 5 March 2026, and six firms have been admitted into a one-year regulatory sandbox while full licensing guidelines remain in drafting. This is assessed at High confidence, corroborated across more than one secondary source and a Bank of Ghana primary notice, and it represents the single most consequential architecture-level shift in Ghana's financial-integrity posture this cycle: a jurisdiction moving from an unregulated, ambiguous crypto posture toward a FATF-aligned licensing perimeter, with the practical effect of bringing an entire asset class within reporting-entity obligations for the first time.

Other Developments

Beneficial-ownership transparency tightens for foreign-linked trading enterprises. The Ghana Investment Promotion Authority Act, 2026 (Act 1173), assented 15 July 2026, repeals the GIPC Act 2013 and removes minimum-capital floors for most foreign investors, but it introduces an anti-nominee beneficial-ownership disclosure requirement specifically for Ghanaian trading enterprises with a non-citizen beneficial owner or director, and it creates a National Investment Registry. This supplements, rather than replaces, the existing Companies Act 2019 ORC register, and is assessed at Assessed confidence pending independent retrieval of the statutory text, which currently rests on a single Tier-3 source.

Galamsey gold smuggling remains a structurally significant leakage channel. The IMF is reported to estimate approximately 229 tonnes of artisanal gold, worth roughly US$11.4 billion, smuggled out of Ghana between 2019 and 2024. Government response has been architecture-level — removal of ASGM taxation in 2025 and creation of the Ghana Gold Board (GoldBod) to conduct responsible-sourcing and AML checks on artisanal gold purchases — but enforcement-gap commentary persists, and this development is assessed, not confirmed, given reliance on secondary reporting of the underlying IMF figures.

GIABA's third-round mutual evaluation of Ghana completes its on-site phase. GIABA's on-site visit ran from 26 January to 6 February 2026, assessing risk understanding, financial-intelligence use, targeted financial sanctions, beneficial-ownership transparency, asset recovery, and inter-agency cooperation. Ghana is the first state assessed under GIABA's third-round calendar, and the final mutual evaluation report is due at the November 2026 Plenary — a High-confidence, Tier-1-sourced development that will formally reset Ghana's AML/CFT/CPF effectiveness and technical-compliance ratings.

Bank of Ghana's sandbox and Virtual Assets Department signal a maturing supervisory posture. The Regulatory Sandbox Framework tests new digital-finance business models, including virtual-asset providers, under real market conditions, and BoG has stood up a dedicated Virtual Assets Department ahead of full VASP licensing — an active-defence and RegTech-adjacent posture assessed from a Tier-1 primary source.

Cross-Monitor Connections

The VASP Act 1154 development is directly relevant to World Payments Monitor coverage of Ghana's stablecoin and digital-money architecture, given the shared regulatory anchor in the Bank of Ghana's Virtual Assets Department. The galamsey gold-smuggling channel is a conflict-finance and extractive-industry-integrity theme with clear resonance for commodity-flow and conflict-finance monitoring, given the transnational financing and foreign-capital involvement independent analysis attributes to the trade. The beneficial-ownership tightening under Act 1173 has a narrower but real read-across to World Payments' merchant and corporate-onboarding due-diligence posture, insofar as trading-enterprise ownership transparency affects counterparty risk assessment for payment-service providers operating in Ghana.

Outlook

The single largest near-term swing factor for Ghana's financial-integrity standing is the GIABA mutual evaluation report, due for adoption at the November 2026 Plenary; its findings on beneficial-ownership transparency, financial-intelligence use, and targeted financial sanctions will likely shape a follow-up action plan. On the crypto side, Bank of Ghana's implementing guidelines for VASP licensing, expected in the second half of 2026, will convert the current registration-and-sandbox posture into a full licensing regime. The galamsey enforcement-gap question — whether GoldBod's creation translates into measurable smuggling reduction — remains the open structural question against the backdrop of an $11.4 billion smuggling estimate that current architecture has not yet visibly closed.

weekly_brief_draft · JID GH
Domain intelligence (D1–D6)

D1 Sanctions

Not covered

Sanctions is not yet covered for this jurisdiction in this report.

D2 Beneficial Ownership and Corporate Transparency

Beneficial Ownership and Corporate Transparency

Continue reading

Ghana's beneficial-ownership and corporate-transparency picture this cycle is anchored in a domestic legislative change rather than in the European Union's supervisory architecture. The Ghana Investment Promotion Authority Act, 2026 (Act 1173), assented 15 July 2026, repeals the GIPC Act 2013 (Act 865) and removes minimum-capital floors for most foreign investors, but it introduces a targeted anti-nominee beneficial-ownership disclosure requirement for Ghanaian trading enterprises with a non-citizen beneficial owner or director, and it establishes a National Investment Registry. This is a narrower instrument than a general corporate-transparency reform: it is aimed specifically at nominee-shareholding risk in foreign-linked trading enterprises, and it supplements rather than displaces the existing Companies Act 2019 (Act 992) Office of the Registrar of Companies beneficial-ownership register. Confidence in this finding is Assessed rather than High, since the statutory text of Act 1173 was not independently retrieved this cycle and reliance rests on a single Tier-3 secondary source; the substance of the anti-nominee test and the registry's operational scope should be treated as provisional pending primary-text confirmation.

Ghana sits outside the European Union's beneficial-ownership supervisory perimeter, so the EU AML Package is contextual backdrop rather than the primary subject matter here. Globally, that package now comprises three distinct instruments: the directly applicable AML Regulation (AMLR, Regulation (EU) 2024/1624), the sixth AML Directive (6AMLD, transposed per Member State), and the AMLA Regulation (Regulation (EU) 2024/1620), which establishes the Anti-Money Laundering Authority and shifts supervision of certain obliged entities from purely national authorities toward a hybrid EU-level direct/indirect-supervision regime. No AMLA-specific horizon anchor touching Ghana was carried in this cycle's research, so this architecture is stated as durable standing context rather than as a Ghana-specific development, and the domain's signal this cycle should be read as locally generated: a national anti-nominee disclosure reform layered onto an existing domestic ORC register, not a spillover from the EU's hybrid-supervision transition.

The obligation created by Act 1173 falls within a Customer Due Diligence control category, targeted at corporate and high-net-worth customer typologies, and maps to FATF Recommendation 24 on the transparency and beneficial ownership of legal persons. The control-gap signal attached to this obligation is partial, reflecting that a disclosure duty now exists in statute but implementation guidance, registry operational detail, and enforcement mechanics have not yet been independently verified.

Outlook

The most consequential near-term development for this domain is not Act 1173 itself but its interaction with the GIABA third-round mutual evaluation, whose on-site phase assessed beneficial-ownership transparency among other pillars and whose findings are due at the November 2026 Plenary; a critical GIABA assessment could either validate or expose gaps in the newly created National Investment Registry before its operational detail is even settled. Watch for independent retrieval of the Act 1173 statutory text, for any GIABA commentary specifically addressing beneficial-ownership transparency in the forthcoming mutual evaluation report, and for whether the National Investment Registry is operationally integrated with the existing Companies Act ORC register or stood up as a parallel system.

D3 Enabler Jurisdictions

Not covered

Enabler Jurisdictions is not yet covered for this jurisdiction in this report.

D4 Conflict Finance and Extractive-Industry Integrity

Conflict Finance and Extractive-Industry Integrity

Continue reading

Ghana's artisanal small-scale gold-mining sector — galamsey — surfaces this cycle as a structurally significant conflict-finance and extractive-industry-integrity channel rather than an episodic enforcement story. The IMF is reported to estimate that approximately 229 tonnes of artisanal gold, worth roughly US$11.4 billion, was smuggled out of Ghana between 2019 and 2024. That scale, if the estimate holds, implies annual leakage in the low billions of dollars flowing outside formal, traceable channels, a magnitude that outstrips episodic enforcement actions and points instead to a structural gap in trade-based and commodity-flow oversight. Confidence in the underlying figure is Assessed, not Confirmed: it is corroborated across secondary reporting but the underlying IMF report itself was not directly retrieved this cycle, so the number should be treated as a directionally credible order-of-magnitude estimate rather than an audited figure.

The government's institutional response has been architecture-level rather than purely punitive. Ghana removed artisanal small-scale gold-mining (ASGM) taxation in 2025 and created the Ghana Gold Board (GoldBod), tasked with responsible-sourcing and anti-money-laundering checks on artisanal gold purchases. This is a genuine structural intervention — a new institutional chokepoint inserted into the gold-purchasing chain — and it maps to FATF Recommendation 24's customer-due-diligence expectations for the sector, with a control-gap signal flagged as uncovered, meaning the CDD control at this point in the value chain is assessed to still be absent in practice rather than merely partial. Independent commentary characterises galamsey financing as increasingly transnational, with foreign capital involvement, and calls for closer cooperation between the Financial Intelligence Centre and customs authorities — a pairing that speaks directly to the architecture-over-incident principle: GoldBod's creation is a necessary but, on current evidence, not yet sufficient structural response to a smuggling channel operating at a scale that predates and so far outpaces it.

This is a three-pillar-relevant finding beyond its AML framing: the trade-based laundering vector interacts with conflict-finance risk to the extent that artisanal mining sites and their financing chains have historically been linked to informal armed actors in West Africa's broader extractive-industry landscape, even though this cycle's evidence base does not specifically confirm such a linkage for Ghana.

Outlook

The open question for this domain is whether GoldBod's responsible-sourcing and AML-check mandate translates into a measurable reduction in the smuggling volume the IMF has estimated, or whether the enforcement gap independent analysts have flagged persists despite the new institutional architecture. Watch for GoldBod's first reporting cycle or any published purchase-volume data that would allow a before/after comparison against the 2019-2024 smuggling baseline, and for whether the FIU/customs cooperation independent commentary calls for is formalised. The GIABA third-round mutual evaluation, due for adoption in November 2026, may also comment on extractive-sector AML controls given the sector's structural significance to Ghana's overall money-laundering risk profile.

D5 Crypto / Digital Assets / Financial Innovation

Crypto / Digital Assets / Financial Innovation

Continue reading

Ghana's Virtual Asset Service Providers Act, 2025 (Act 1154) is this cycle's clearest architecture-level financial-innovation development, and it is now in phased implementation. The Act legalises crypto trading and gives the Bank of Ghana primary licensing authority through a newly created Virtual Assets Regulatory Office/Department, operating in collaboration with the Securities and Exchange Commission and the Financial Intelligence Centre. It mandates customer due diligence, suspicious-transaction reporting to the FIC, and AML/CFT compliance aligned to FATF standards, including Travel Rule duties intended to facilitate cross-border cooperation on virtual-asset transfers. A registration deadline for existing VASPs serving Ghanaian residents passed on 5 March 2026, and six firms have been admitted into a one-year regulatory sandbox, with implementing guidelines reported to remain in drafting as of July 2026. This finding carries High confidence, drawing on corroboration across more than one secondary source together with a Tier-1 Bank of Ghana primary notice.

The compliance-technology dimension of this shift is notable in its own right: the Bank of Ghana's Regulatory Sandbox Framework tests new digital-finance business models, including virtual-asset providers, under real market conditions, and BoG has stood up a dedicated Virtual Assets Department to supervise the sector ahead of full licensing. Read together with the VASP Act itself, this represents a genuine active-defence and RegTech-forward supervisory posture rather than a purely reactive one: Ghana is building supervisory capacity concurrently with, rather than after, the legal architecture that will require it.

The practical AML/CFT significance of this shift is that an entire previously unregulated asset class is being brought within reporting-entity obligations for the first time, materially expanding the population of institutions subject to CDD and STR duties in Ghana's financial system. This is exactly the kind of structural, architecture-level development that a purely enforcement-volume-weighted read of AML/CFT activity would under-weight, since no crypto-specific enforcement action has yet been generated by the new regime — the significance lies in the legal and supervisory scaffolding being put in place, not in an incident count.

Outlook

The near-term swing factor is publication of the Bank of Ghana's full VASP licensing and supervisory guidelines, expected in the second half of 2026, which would convert the current registration-and-sandbox interim posture into a complete licensing regime. Watch for the substantive content of those guidelines — particularly around Travel Rule implementation thresholds and cross-border VASP counterparty due diligence — and for whether the six-firm sandbox cohort graduates into full licences on a timeline consistent with the Act's implementation calendar.

D6 Compliance Technology & Active Defence

Not covered

Compliance Technology & Active Defence is not yet covered for this jurisdiction in this report.

D7 AML/CTF Regime

Not covered

AML/CTF Regime is not yet covered for this jurisdiction in this report.

Regulatory horizon
Consultation2026-Q4 · ±half_year

Bank of Ghana VASP Act 2025 implementing guidelines

Publication of BoG's phased VASP licensing/supervisory guidelines will convert the registration-and-sandbox posture into a full licensing regime.
In Force Pending2026-Q4 · ±quarter

GIABA 3rd-Round Mutual Evaluation of Ghana — final report adoption

Adoption of the MER at the November 2026 GIABA Plenary will set Ghana's formal AML/CFT/CPF effectiveness and technical-compliance ratings, potentially triggering a follow-up action plan.
2 dated · 4 pending date · baseline financial-integrity-2026-07-05
Role action cards
MLROHigh

VASP Act 2025 phased rollout and galamsey CDD gap materially expand and stress Ghana's reporting-entity population.

A new class of virtual-asset reporting entities now carries CDD and STR duties to the FIC, while the galamsey gold-purchasing chain remains a flagged uncovered CDD control gap despite GoldBod's creation. The GIABA mutual evaluation due November 2026 will test whether these obligations are being met in practice.

3 evidence refs
ComplianceAssessed

Three parallel Ghanaian control frameworks — VASP licensing, BO disclosure, and gold-sector CDD — are all mid-build this cycle.

None of the VASP licensing guidelines, the Act 1173 BO disclosure mechanics, or GoldBod's AML checks are yet fully operational, meaning obliged-entity exposure in Ghana currently sits in a transitional, partially-controlled state across three distinct regimes.

3 evidence refs
LegalAssessed

Act 1173's anti-nominee beneficial-ownership test and the pending GIABA MER both carry unresolved liability-exposure implications.

The statutory text of Act 1173 has not been independently retrieved, and the GIABA MER's findings on beneficial-ownership transparency could trigger follow-up legislative action; both are live legal-exposure watch items rather than settled positions.

2 evidence refs
BoardHigh

Galamsey's $11.4bn smuggling estimate and the VASP Act's licensing shift are the two material financial-crime-risk headlines for Ghana this cycle.

The scale of gold-smuggling leakage and the GIABA mutual evaluation outcome due November 2026 are the two developments most likely to affect Ghana's overall reputational and regulatory standing at board level.

3 evidence refs
CTOAssessed

Bank of Ghana's Virtual Assets Department and six-firm sandbox define the near-term crypto-infrastructure compliance environment.

Technical integration with any VASP counterparty in Ghana should anticipate Travel Rule and CDD data-field requirements once BoG's implementing guidelines publish, and should track the sandbox cohort's evolution.

2 evidence refs
RiskHigh

Galamsey smuggling scale, VASP Act rollout, and BO-disclosure tightening together mark three emerging exposure-concentration vectors for Ghana.

Trade-based laundering via artisanal gold, a newly regulated crypto sector, and foreign-linked trading-enterprise ownership structures are three distinct but simultaneously developing risk vectors this cycle, warranting cross-monitor escalation tracking.

3 evidence refs
OperationsAssessed

New CDD, STR, and Travel Rule workflows are required for Ghana-linked VASP counterparties and foreign-linked trading enterprises.

Screening and onboarding processes touching Ghanaian virtual-asset counterparties or non-citizen-owned Ghanaian trading enterprises should anticipate new documentation requirements once implementing detail publishes.

2 evidence refs
AuditPossible

GIABA's third-round mutual evaluation functions as an external control-testing event for Ghana's AML/CFT architecture.

The GIABA on-site assessment and BoG's sandbox/Virtual Assets Department build-out both offer external and internal reference points for testing whether Ghana's current AML/CFT and crypto-supervision controls are documented and operating as described.

2 evidence refs
Decision lens
MLRO

VASP Act 2025 phased rollout and galamsey CDD gap materially expand and stress Ghana's reporting-entity population.

Compliance

Three parallel Ghanaian control frameworks — VASP licensing, BO disclosure, and gold-sector CDD — are all mid-build this cycle.

Legal

Act 1173's anti-nominee beneficial-ownership test and the pending GIABA MER both carry unresolved liability-exposure implications.

Board

Galamsey's $11.4bn smuggling estimate and the VASP Act's licensing shift are the two material financial-crime-risk headlines for Ghana this cycle.

CTO

Bank of Ghana's Virtual Assets Department and six-firm sandbox define the near-term crypto-infrastructure compliance environment.

Risk

Galamsey smuggling scale, VASP Act rollout, and BO-disclosure tightening together mark three emerging exposure-concentration vectors for Ghana.

Operations

New CDD, STR, and Travel Rule workflows are required for Ghana-linked VASP counterparties and foreign-linked trading enterprises.

Audit

GIABA's third-round mutual evaluation functions as an external control-testing event for Ghana's AML/CFT architecture.

Shared evidence: 6 refs
Scenario sketches

AMLA direct/indirect supervision transition — illustrative structural shift

Illustrative orientation only: as the AMLA Regulation (Reg (EU) 2024/1620) phases in alongside the directly applicable AMLR (Reg (EU) 2024/1624) and per-state 6AMLD transposition, cross-border obliged entities could see supervision migrate from purely national authorities toward a hybrid EU-level direct/indirect-supervision model. This could, illustratively, reshape how enabler-jurisdiction and beneficial-ownership typologies are supervised for entities with EU-facing exposure, though Ghana itself sits outside this perimeter and no Ghana-specific AMLA horizon anchor was identified this cycle.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Standing trackers (T1–T6)
TrackerStatusNote
T1 · Russian Sanctions-Evasion Architectureno_changeNo GH nexus identified this cycle.
T2 · EU AML Package / AMLAno_changeNot applicable — Ghana outside the EEA/EU regime.
T3 · FATF Grey ListwatchGhana not on the increased-monitoring list; GIABA 3rd-round MER on-site complete, adoption expected November 2026 Plenary — a status-defining event to watch.
T4 · Beneficial-Ownership Register Statusmaterial_changeGIPA Act 2026 (Act 1173) adds anti-nominee BO test for trading enterprises; Companies Act 2019 (Act 992) ORC register continues.
T5 · Crypto & Digital-Asset Integritymaterial_changeVASP Act 2025 (Act 1154) in phased implementation; registration deadline 5 March 2026; six-firm sandbox cohort.
T6 · Sanctions Regime Divergenceno_changeNo GH-specific sanctions designation or divergence event identified this cycle.
Registers

Enforcement actions

  • OFAC designated Garantex co-owner Aleksandr Mira Serda, alongside Sergey Mendeleev, Pavel Karavatsky, InDeFi Bank, Exved, Grinex, Old Vector and A7/A71 LLC, for building sanctions-evasion crypto infrastructure supporting Russian ransomware and darknet-market laundering. 14 Aug 2025
  • Ghanaian authorities arrested three Indian nationals accused of smuggling gold out of Ghana over roughly a decade, part of broader enforcement pressure on illicit gold export channels tied to the galamsey economy. 29 Apr 2025
  • Operation Serengeti 2.0, running June-August 2025 across 18 African countries and the UK, acted on TRM Labs blockchain-intelligence leads to pursue Bl00dy ransomware laundering infrastructure identified as active in Ghana, alongside broader ransomware, scam and business-email-compromise disruption. 1 Aug 2025
  • Ghana's dedicated task force 'Operation Halt' conducts raids and arrests of illegal miners as part of the National Action Plan on Environmental Crimes (2023-2027), targeting galamsey operations linked to illicit gold flows and water/forest destruction. 25 Apr 2025

Sanctions changes

  • OFAC's 14 August 2025 designation named Aleksandr Mira Serda (alternate nationality Ghana, formerly known as Ntifo-Siaw), a Garantex co-owner, under Russia-related sanctions authorities for building crypto sanctions-evasion infrastructure (Grinex, A7A5 token, InDeFi Bank, Exved). 14 Aug 2025
  • The EU Commission's high-risk third-country delegated regulation updates of June 2025 and December 2025 added or delisted several West/Central African peers (Cote d'Ivoire, Kenya added June 2025; Burkina Faso, Mali, Nigeria, South Africa, Tanzania delisted December 2025) but did not add or reference Ghana at any point in the window, keeping Ghana outside the EU high-risk list even as regional peers moved on and off it. 4 Dec 2025
  • Across the October 2025, February 2026 and June 2026 FATF Plenary cycles, Ghana was not among the jurisdictions reviewed or newly identified for increased monitoring, confirming its continued absence from the grey list since its June 2021 delisting while it remains formally in GIABA's enhanced follow-up process for outstanding technical-compliance items. 19 Jun 2026

Regulatory horizon (register)

  • Ghana VASP licensing regime full rollout after SEC pilot
  • GIABA follow-up review of Ghana's enhanced-monitoring status
  • Next FATF Plenary grey-list review cycle
  • National Action Plan on Environmental Crimes 2023-2027 target completion

Active schemes

  • [HIGH] Galamsey gold smuggling and TBML
  • [HIGH] Garantex/Grinex/A7A5 sanctions-evasion crypto nexus
  • Ransomware laundering infrastructure hosted in Ghana
  • Beneficial-ownership verification gap at Registrar-General
Sources
  1. FATF
  2. FATF
  3. GIABA (FATF-style regional body, first-party assessment of Ghana)
  4. Government of Ghana (Anti-Money Laundering Act, 2008, Act 749)
  5. European Commission
  6. European Commission
  7. HM Treasury (OFSI)
  8. US Treasury OFAC
  9. ICIJ
  10. ICIJ
  11. TRM Labs
  12. Bloomberg
  13. Bloomberg
  14. UNODC
Coverage gaps
The Companies Act's beneficial-ownership obligations on the …
The Companies Act's beneficial-ownership obligations on the Registrar-General's Department were, per GIABA's assessment, not yet implemented at the point of review, and ownership information for foreign legal persons remains difficult for investigators to obtain, leaving BO registry data of uncertain current completeness and verification quality.
GIABA's evaluation found weak compliance by DNFBPs and some …
GIABA's evaluation found weak compliance by DNFBPs and some non-bank financial institutions with reporting obligations, limiting the volume and quality of suspicious transaction reports reaching the Financial Intelligence Centre, and standalone/third-party money-laundering prosecutions (as opposed to self-laundering tied to predicate offences) remain rare.
UK Home Office country guidance notes that data on arrests a…
UK Home Office country guidance notes that data on arrests and prosecutions in Ghana is limited and the government does not make such information publicly available, constraining independent assessment of current AML/CFT enforcement effectiveness beyond periodic GIABA/FATF review cycles.
Despite the National Action Plan on Environmental Crimes (20…
Despite the National Action Plan on Environmental Crimes (2023-2027) and task forces such as 'Operation Halt', the scale of galamsey-linked illegal gold mining and associated smuggling/TBML continues to outpace enforcement capacity, with Ghana estimated to lose billions of dollars annually to related illicit gold flows.

Evidence

Confidence-tiered claims

No structured claims published for this jurisdiction yet.