Introduction
In Gold Supply Flowchart: Part 1—Before Goldbod, we run through the gold supply structure that prevailed prior to establishing the Ghana Goldbod Act. The evolution of the local gold supply chain as outlined in there, occurred over time. However, most of the more political developments happened after 2020. The Ghana Gold Board Act (Act 1140) was passed on April 2, 2025. This marked the dawn of a new era in the local gold supply system.
Some notable changes were introduced under this new regime. Let us go through the most pivotal ones:
1. PMMC to Goldbod
The Precious Minerals Marketing Company (PMMC), the predecessor of Goldbod, at various times engaged in assaying, trading, and exporting gold. As a state enterprise, the PMMC competed with private sector businesses as one of the many players on the local gold free market. All parties competed relatively fairly based on who offered the most competitive prices, the most efficient services, or the best customer experience.
Precious Mineral Marketing Company
At the time of introducing the Gold Board Act, the official role of the PMMC was the National Assayer. This mandate empowered the PMMC to assay all gold exports and charge a fee for that service—specifically, 0.2524% of the value of the gold being exported. The National Assayer was also mandated to collect other taxes, including export taxes on behalf of the state.
That apart, the PMMC was also engaged in local gold purchasing on behalf of the Bank of Ghana in an unofficial capacity, along with selected private sector gold traders. This mandate was activated under the Domestic Gold Purchasing Program (DGPP), which was popularly referred to as Gold for Oil (G4O), which was introduced by the immediate past government in mid-2022.
Domestic Gold Purchasing Program
Before the DGPP was introduced, the PMMC was not an active gold trader. In 2016, PMMC’s gold trading rights were revoked after it had recorded billions of United States Dollars in gold trade-related losses. The Bank of Ghana (BoG) was responsible for this revocation, as it was the state institution tasked with issuing gold trade licenses at the time. Interestingly, the losses and the resulting revocation occurred only a few months after the BoG had designated PMMC the sole exporter of Gold.
It is important to know that the power of the Bank of Ghana to issue trading licences was backed by law, specifically, the Bank of Ghana Act (Act 612), 2002. Section 50(d) of this Act empowered the BoG to “import, export, refine, hold, sell, transfer or otherwise deal in gold, gold coins and bullion, silver, platinum and any other precious metals as determined by the Board”. By this provision, the BoG could also regulate transactions involving precious minerals and license third parties to carry out its mandate in the gold industry.
Over time, the responsibility of issuing trading licenses shifted from BoG to PMMC, which was not amiss, since the existing Precious Minerals Marketing Corporation Law (PNDC Law 219), 1989 also authorized the PMMC to grade, assay, value, process, buy and sell precious minerals, as well as to license agents. For clarity, the Minerals Commissions’ (MinComm) mandate is focused on regulating on the extractive sector, ie, regulating the mining sector and issuing mineral rights. In addition to this mandate, the Minerals and Mining Act, (Act 703), 2006 empowered MinComm to grant gold export licenses.
The Ghana Gold Board
The Gold Board Act has shifted the mandate of issuing export licenses from MinComm to Goldbod. More importantly, the mandates, responsibilities, assets, and liabilities of PMMC have been inherited by the Goldbod, since Goldbod is an offshoot of PMMC. The history of the PMMC cannot be divorced from the Goldbod, notwithstanding the change in name, leadership, and parent law. Also, additional powers, mandates and structures have been added to the Goldbod which did not exist in PMMC. We shall delve into these in the following points.
2. State Monopoly of the Local Gold Trade Industry
The Ghana Gold Board Act (Act 1140), 2025 imbues the Goldbod with the “sole authority to grade, assay, weigh, value, purchase, sell and export gold” produced by artisanal and small-scale mining (ASM) companies in Ghana. The mandate extends to having the right of pre-emption over “a portion or all of the gold produced by large scale mining companies”.
The exclusive rights accorded Goldbod triggers memories from 2016 when the Bank of Ghana declared PMMC the sole buyer of ASM gold. No need re-echoing how that ended. To be fair, past experience does not guarantee future results. It would therefore not be proper to assume that the operationalization of Goldbod’s exclusive rights would yield disastrous results as we saw in 2016. The difference in leadership, strategy, and overall competence may very well lead to an entirely different outcome. Time will tell.
The list of licenses issuable by the Goldbod suggests that the institution’s mandate also covers storage, transportation, refining and fabrication of ASM gold. Whether these areas are part of its exclusive mandate are unclear. Other existing legal provisions across the precious minerals industry, some of which were mentioned in previous chapters, empowered the related state institutions to issue licenses as a means to regulate, monitor and streamline the activities of businesses involved in the industry.
The framers of the Acts of Parliament in question did not see the need to include provisions that categorically declare the related state institutions as having the exclusive right operate in those areas they are mandated to regulate. They simply provide that, all relevant agencies and entities are required to obtain licenses from these state authorities or regulators, and operate only within the framework of the licenses obtained.
It is a significantly different approach when the law provides that a given state entity has the exclusive authority to operate in an industry, and then imbues the same entity with the power to license private agencies to carry out these exclusive activities on its behalf. This clearly is the approach of the Gold Board Act. The only other state institution in Ghana that has a similar legal framework is the Ghana Gocoa Board (Cocobod). Assumably, this similarity is no coincidence, given the similarity in nomenclature.
Whether or not there is a tangible difference in the operationalization, efficiency or compliance levels of these two types of approaches is a matter that bears study. Nevertheless, this write-up is not intended to prove the efficiency or viability of the Goldbod approach. Rather, the intention is to lay bare the facts so that the reader can make an informed judgement.
3. An Expanded Licensing Regime
Precious Metals Marketing Company (PMMC), the predecessor of Goldbod, was mandated to issue exactly one licence at the time the Ghana Gold Board Act was passed. That is the gold trader licence. This licence was required by all agents or agencies who desired to participate in Ghana’s local gold trade industry. The new Act gives the Goldbod the responsibility of issuing a total of ten (10) licenses.
This is the list of the licenses issuable by the Goldbod:
- Aggregation License
- Buying License
- Refining License
- Export Partnership License
- Storage License
- Importation License
- Transhipment License
- Transportation License
- Smelting License
- Fabrication License
Exactly two weeks after the Gold Board Act was passed, the Goldbod opened applications for two out of the ten licenses—the Aggregator Licence and the Buyer License. Details on the two licenses, including operational, financial, governance and legal requirements were made available to the public, including an online application portal. Goldbod announced that six out of the remaining eight licenses would be open for applications from July, 2025. Unfortunately, the scope and requirements of these six licenses have not been made available. Neither is there any information on the remaining two licenses, ie, the Export Partnership License and the Transhipment License.
There are two types of Aggregator Licenses—Aggregator License, and Self-financing Aggregator License; and two types of Buyer Licenses— Tier 1 Buyer License, and Tier 2 Buyer Licence.
The increase in the number of licenses issued by the Goldbod’s is a result of several factors. The PMMC-issued gold trader license was separated into Aggregator Licence and Trader License; further divided into two licenses each. The Refinery License and Export License were moved from MinComm to Goldbod. Till information on the scope is provided, we would presume the Export Partnership License is the same as the Export License.
Storage License, Transportation License, and Fabrication License were moved from the Ghana Police Service to Goldbod. Smelting License is an entirely new license category, within the scope of other licenses. Importation and Transshipment Licenses did not exist before either. Again, it is not obvious that a larger number of licenses would lead to better rationalization, greater efficiency, or more compliance. Let time be the judge.
