By Bright Simmons, Vice President, IMANI Africa
Ahead of the holidays, I posted on Twitter (X) about the IMF’s disclosure that Ghana’s state-owned monopoly gold exporter and trader, GoldBod, has made trading losses of about $214 million.
That act prompted the CEO of GoldBod to respond, and in a most emphatic and categorical manner. He disputes every notion of “losses”. I had to come back and set the records straight. The IMF was absolutely precise and emphatic. There had been trading losses.
Anyone can read the fifth review here and check out precisely what the IMF said.
The reason why the IMF has become sacrosanct in these matters is that some governments, such as the government of Ghana (GoG) share data with them that they will never share with any other institution in their own country. Political Activists can bash the IMF all they want. So long as domestic governments choose this conduct, the IMF will remain the last-resort arbiter of facts.
In this case, though, there is no reason for even bashing the IMF in the first place. They have no reason to lie about a major policy initiative of their client government because they have been aggressively positioning Ghana as a success story.
When, therefore, they express concern about some particular policies, it is very likely that they fear that it does indeed have the potential to derail that success story.
By inviting us to distrust the IMF, the GoldBod is basically inviting doubt about all the other nice accounts the IMF has been giving about the Ghanaian economy. A serious recipe for confusion among investors. I wonder why the CEO of GoldBod thought that this is a politic and strategic thing to do, and why the Minister of Government Communications did not step in to ensure cross-government consistency of narrative. Anyways.
Now that I have been snapped out of holiday mood, I might as well respond to the flurry of inquiries I saw on Twitter.
What exactly did the IMF say?
First, they began by reminding everyone about a major risk some of us have pointed out about the GoldBod: it is diverting most gold dollars away from the commercial banks to the central bank.
Here is how they put it:
“Ghana’s FX market has long been hampered by macroeconomic imbalances, shallow interbank activity, and a lack of transparency in BoG’s FX operations. The large and increasing share of FX inflows captured by the BoG limited market depth and price discovery.”
They then proceeded to make the now famous disclosure:
“The now-discontinued G4O component of the DGPP generated losses of US$128 million (0.15 percent of GDP) in 2024, 30 percent of which emanated solely from the sale of US$0.8 billion in gold. In 2025 through end-Q3, losses from the artisanal and small-scale (ASM) doré gold transactions component of G4R have reached US$214 million (0.2 percent of GDP), mostly on trading losses but also on GoldBod off-takers’ fees.”
They clarified in a footnote that:
The BoG purchased US$7.6 billion in gold through the DGPP in 2025 through August, including US$5 billion of doré gold from ASM miners between April and August. GoldBod charges a 0.5 percent ad valorem service on the BoG’s purchases, as well as a 0.258 percent assay fee.
These are very specific quantitative claims. In what universe can this be described as suggesting anything other than trading losses in the GoldBod’s operations? Even in “everything is debatable” Ghana, this controversy is rather bizarre.
It is clear that GoldBod charges the Bank of Ghana for delivering assaying (gold purity testing) and middle-man services (about 0.758% of the value of gold it buys for BoG) but whenever any losses arise from mistiming (gold price moving between purchase and sale), premia paid to aggregators to entice delivery of large and consistent volumes, and/or discounts given to big buyers, GoldBod simply transfers those liabilities to the Bank of Ghana.
Here is a hypothetical breakdown of how such liabilities might occur.
Component Amount (USD) Beneficiary/bearer
Spot Price $4,000.00 —
Purchase Price paid to Miner $4,000.00 (as close to LBMA spot price as possible to avert smuggling) ASM Miner
Sales Price (Intl. Refiner) $3,880.00 BoG (Inflow)
Trading Spread Loss ($120.00) BoG (Loss)
GoldBod Service Fee (0.5%) ($20.00) GoldBod (Revenue)
GoldBod Assay Fee (0.258%) ($10.32) GoldBod (Revenue)
Total BoG Loss per Ounce ($150.32) Central Bank Balance Sheet
How this is going down: BoG moves and IMF’s likely counter-moves
We now understand from insiders that the Bank of Ghana’s rather odd statement suggesting that the IMF was being “speculative” about the losses and that everyone should wait until the BoG’s books are audited is due to discussions with their auditors about possible “accounting treatments” that might classify the trading losses under some other label.
On that score, they are constrained by the fact that the IMF also influences the very accounting standards that they abide by.
Here are the key accounting blueprints that the IMF has their fingerprints on:
Balance of Payments and International Investment Position Manual (BPM6)
Government Finance Statistics Manual (GFSM 2014)
IMF Safeguards Assessment Framework
International Financial Reporting Standards (IFRS) as adapted for central banks
IMF programme conditionality and reporting templates
Because some of the gold bought by GoldBod for the Bank of Ghana (BoG) sits in their reserves, and the price of gold is still rising, the BoG is said to be exploring “revaluation gains.” However, BPM6 and safeguards assessments explicitly require separation of realised trading results from valuation effects. They can park volatility temporarily, but persistent negative cashflow cannot live forever in a revaluation account. And mark-to-market in this fashion can always turn against BoG anyway when prices flip.
The other approach would be to book the losses as claims on the central government (essentially, the Ministry of Finance.) Under IMF rules, this converts a monetary loss into a quasi-fiscal operation. The Fund then requires:
explicit recognition in fiscal accounts, or
a time-bound plan to settle the receivable.
This is exactly why the IMF stated thatDGPP / Gold-for-Reserves losses should be brought on budget. Essentially, Hon. Ato Forson needs to man up and take one on the chin for the government.
Once the central bank is the cash/liquidity provider to the GoldBod:
any losses affect central bank capital,
impair policy credibility,
and potentially violate central bank independence norms.
IMF safeguards are particularly strict here. That is why they decided to mention the issues in their review, the content of which is always agreed with the government before publication.
Once the IMF has:
quantified losses,
attributed them to specific channels (trading losses and off-taker fees),
and recommended budgetary treatment,
the Bank of Ghana has four options really:
Disprove the IMF numbers with transparent reconciliations
(publish weights, realised prices, costs, and FX timing).
Accept the losses and fiscalise them explicitly (i.e. pass the troubles on to Hon. Ato Forson as on-budget subsidy for policy goals).
Scale down or redesign the programme
(reduce BoG exposure and change GoldBod’s role – the BoG hints at that).
Persist with opacity but be willing to absorb the following risks:
adverse IMF programme reviews,
stricter safeguards conditions,
reputational damage,
eventual forced disclosure anyway.
Dealing with the ~$10 billion “gain” narrative
In the wake of the controversy, many of the GoldBod’s supporters have accused analysts of refusing to appreciate the billions of dollars “brought into the economy” by the GoldBod.
The government’s decision to double down on the Domestic Gold Purchase Programme (DGPP) and the Gold-for-Reserves (G4R) initiative, has been publicly celebrated as the catalyst for stabilizing the Cedi and expanding Gross International Reserves (GIR) to approximately US$11.4 billion by December 2025.The narrative advanced by GoldBod lovers, and the organisation itself, is one of unqualified success. Literally every good thing that has happened to the economy has been due to GoldBod’s interventions.
On December 24th of this year, the GoldBod reminded the public that its actions has led to the export of more than 100 tons of small-scale and artisanal gold and generated over $10 billion worth of exports.
There is no doubt that the GoldBod has succeeded on the volume front. There were indeed fears that attempts to force the entire supply chain to shift to a single, government-controlled, channel might throttle supply. This obviously has not happened. But the same factors accounting for the volume “success” seem to be the ones generating the losses: by offering premia, which it calls “bonuses”, to favoured super-aggregators like Bawa Rock and discounts to super offtakers like Pinnacle DMCC of the UAE and Sovereign Metals of India, whilst heavily concentrating buying and selling within this small cohort, GoldBod has boosted volume but lost significant money on transactions.
The need to pump dollars at regular intervals to support the BoG’s market intervention goals regardless of spot market price dynamics mean that GoldBod and BoG have had to be tolerant of losses. This is the price one pays for the policy choice of diverting all the small-scale gold dollars from commercial banks to the government.
The table below explain some of the dynamics at play. It relates mostly to Q2 and Q3 2025 trading dynamics of the GoldBod.
Destination Market Aggregated Value (USD) Share of Trade Strategic Rationale
United Arab Emirates (Dubai) $314,560,000 ~54.2% Insight: The UAE acts as the clearinghouse for immediate USD generation. Buyers here (Pinnacle, IFC) are traders/aggregators who settle fast.
India $209,140,000 ~36.0% Insight: India represents end-user demand. Buyers here (Sovereign, Augmont) are industrial refiners feeding the jewelry market.
Switzerland $56,867,000 ~9.8% The Legacy Exit: Represents the final liquidation of relationships with MKS PAMP. No significant flows observed after July.
TOTAL SAMPLED ~$580,567,000 100% Note: This represents specific high-volume days analyzed, not the total quarterly output.
In Q4 2025, for instance, one can see clearly the impact of the policy choices dominating normal commercial considerations.
Period Estimated Volume (USD) Primary Driver Confidence Level
July (Transition) ~$150M – $200M Clearing legacy Swiss deals; piloting Dubai corridor. Medium
August (Ramp-up) ~$300M – $400M Operationalizing Pinnacle I DMCC channel ($103M day on Aug 22). High
September (Peak) ~$500M – $600M Q3 Window Dressing; massive Sept 30 clearing ($208M). High
October (Sprint) ~$600M+ Diwali seasonal demand; high frequency trading. High
Q4 Projection >$1.8 Billion Full maturity of the “Gold-for-FX” machine. Medium-High
What is happening is really simple: trying to manage policy objectives and commercial logic within the same structure will sometimes lead to contradictions. If policy wins, commercial performance may have to be sacrificed. What happened on September 30th, according to our informants, was a classic example of policy stress straining commercial logic.
A critical anomaly identified in the forensic data is the export surge on September 30, 2025. On this single day, coinciding exactly with the end of the third quarter, GoldBod is reported to have exported a massive US$208.1 million in gold. This transaction bears all the hallmarks of “window dressing.” By liquidating physical inventory on the final day of the reporting period, the central bank was able to convert “Inventory” (Gold) into “Cash and Cash Equivalents” (USD). This optical transformation must have been aimed at glamourising the liquidity ratios reported to the IMF and rating agencies, projecting a healthier solvency picture than might exist if the assets were held as illiquid doré bars.
Assuming all the facts are borne out, this behavior suggests that the BoG is managing its reserves to meet specific external compliance metrics rather than solely for long-term value preservation. It implies a system under stress, requiring perfectly timed liquidations to satisfy the conditionality of the IMF’s ECF program.
The IMF is thus right to call the whole caboodle “quasi-fiscal activities” and demand explicit treatment on central government books. These are subsidies being paid to advance certain policy goals, including dressing up the books to look good. The government has the discretion to pursue such goals and should just own up to the cost.
But let’s not exaggerate the effect of the GoldBod
None of us can deny that despite Ghana being Africa’s leading gold producer, the state possessed negligible physical gold reserves for most of this decade. In 2021, the Bank of Ghana held a mere 8.7 tonnes of gold in its vaults, a figure that offered virtually no liquidity buffer when global headwinds struck. Some argue that the resulting currency crisis, which saw the Cedi depreciate by nearly 54% against the US Dollar in 2022, was exacerbated by the disconnect between the nation’s mineral output and its monetary reserves. Whatever views one holds, one cannot deny that no one in Ghana has been too happy about how gold has been managed.
That is why despite unease about the opacity and shadowy dealings in the state-driven gold trading programs such as the “Gold-for-Oil” (G4O) program and others, the general public has been general supportive. The subsequent passage of the Ghana Gold Board Act (Act 1140) in April 2025 which institutionalized the state-driven gold trading approach, granting GoldBod the exclusive authority to buy, assay, and export gold from the Artisanal and small-scale gold mining sector (ASM sector), was also relatively popular despite analysts warning about risks inherent in how GoldBod was designed.
Since GoldBod took off, it has dispelled at least one fear: volumes from the ASM sector has not collapsed. It has surged on the back of a massive global price rally. But it is important that this fact does not lead us to exaggerate its impact and effectiveness. We have historical parallels that counsel against doing that.
The operational period of GoldBod (2025) coincides with an unprecedented bull market in gold. Historical data indicates that the average annual gold price in 2018 was approximately US$1,269 per ounce. By late 2025, gold prices had surged to averages exceeding US$3,436 per ounce, with daily peaks breaching US$4,500. This represents a price increase of roughly 170% to 250% over the baseline period.
Consequently, any year-over-year comparison of export revenue is inherently misleading without adjusting for this massive price inflation. A static volume of gold exported in 2025 would generate nearly triple the revenue of the same volume exported in 2018, purely due to global market dynamics.
To isolate the efficiency of GoldBod, we must ask: What would Ghana’s gold revenues have looked like under the old regime, given 2025 prices?
Historical Peak Production (2018): Ghana produced a record 148 tonnes of gold in 2018.
Benchmarking with 2025 pricing: If the 2018 production volume (148 tonnes or ~4.76 million ounces) were exported at the 2025 average price of US$3,436/oz, the total value would be approximately US$16.35 billion. This is very much in the range of 2025’s numbers.
The “US$10 billion” figure touted by GoldBod, while substantial for the ASM sector, must be benchmarked against similar volume surges in the recent past before the GoldBod was created. Between 2023 and 2024, ASM gold output doubled, for instance. That growth level is possibly higher than we have seen since GoldBod became fully active sometime in July this year.
The “GoldBod Effect,” therefore, is not the creation of new value, but rather the partial capture of an existing valuation surge. The state is riding a tidal wave of global inflation and safe-haven demand. It did not, however, create the wave.
We must also remember that mineral production volumes expand merely because of price increases.
The surge of ASM output to 100 tonnes is likely less a function of GoldBod’s regulatory genius and more a function of the price elasticity of supply. At US$4,000+ per ounce, marginal and informal mines (“galamsey”) become hyper-profitable, leading to an explosion in activity. GoldBod’s role has been to act as the funnel for this price-induced supply shock, rather than the architect of the production increase itself.
Metric 2018 (Historical Peak) 2023 (Pre-GoldBod) 2025 (GoldBod Era)
Total Production (Tonnes) 148.0 125.5 ~158 (Projected)
Avg. Gold Price (US$/oz) $1,269 $1,943 ~$3,436
Nominal Export Value ~$6.0 Billion ~$7.6 Billion ~$15+ Billion (Projected)
Value at 2025 Prices $16.35 Billion $13.86 Billion TBD
BoG Reserves (Tonnes) ~8.7 ~19.5 ~38.04
Analysis: The data in the table above demonstrates that while reserves have grown due to policy (securitization of gold), the total export value is largely a function of price. The 2018 production levels, if achieved today, would generate revenues exceeding current GoldBod performance, suggesting that capacity utilization remains a challenge.
Some other emerging risks
The exigencies of the “Gold-for-FX” liquidity machine is also driving a massive overcentration as mentioned in my Twitter post.
Given the GoldBod’s current state of operations, it is understandable that it cannot be pursuing LBMA good delivery type arrangements with Swiss refineries that are bound by stringent OECD Annex II due diligence protocols and Swiss Precious Metals Control laws. Such refineries require exhaustive “Know Your Customer” (KYC) checks on the origin of gold to prevent the laundering of illegal or conflict minerals that we have to admit GoldBod cannot provide. Also their compliance burden creates settlement latency (days or weeks before USD FX flows) that the Bank of Ghana cannot afford.
In contrast, the Dubai-India axis that the GoldBod has locked onto offers T+0 or T+1 settlement. Typically, things run this way:
GoldBod exports doré to Dubai aggregators.
Dubai traders often pay 80 – 90% of the value immediately upon assay, providing the instant dollar liquidity the BoG requires for its weekly currency auctions.
The Dubai aggregators (such as Pinnacle I DMCC) often act as intermediaries, refining or swapping the gold and re-exporting it to India to meet industrial jewelry demand.
Whilst the GoldBod’s operational choices are understandable in the suboptimal context in which it is operating, the current approach has introduced a dangerous concentration of counterparty risk.
Our analysis reveals that a single private entity, Pinnacle I DMCC, imported over US$733 million from Ghana in a few quarters in 2025 alone. As the chart above shows, not only is 99% of gold locked to the Dubai-India axis, virtually all the gold is being bought by 4 to 5 offtakers.
While no such risk is imminent, it is still important to realise that Ghana has effectively outsourced its national liquidity generation to a few companies, such as a private trading house in the Dubai Multi Commodities Centre (DMCC). If, say, Pinnacle I DMCC were to face sanctions, banking severance, or a liquidity crisis, Ghana’s primary foreign exchange artery would be severed instantly.
Furthermore, the entire operation has become locked to high and ever-rising gold prices. Should the revaluation mindset take too strong a hold at the BoG, risks could exacerbate. Let me explain.
While the accumulation of 38.04 tonnes of gold is a logistical achievement, it also transforms the Bank of Ghana into a kind of commodities hedge fund if it starts to rely on revaluation gains rather than value preservation as its primary reserve policy anchor. The central bank’s solvency becomes inextricably linked to the volatility of the gold price when that mindset dominates.
A simple scenario should clarify
Gold Holdings: 38.04 tonnes (~1.223 million troy ounces).
Current Price (Baseline): ~$4,500/ounce (Peak 2025).
Total Reserve Value: ~$5.5 Billion.
If the gold price corrects by 30% (falling to ~$3,150/ounce), the impact on the BoG’s balance sheet would be catastrophic.
New Reserve Value: ~$3.85 Billion.
Direct Valuation Loss: ~$1.65 Billion.
Solvency Impact: The BoG, already managing negative equity from the Domestic Debt Exchange Programme (DDEP), would see a further erosion of its asset base. More critically, the flow of FX liquidity from exports would shrink by 30%, while import demand for fuel and medicine remains inelastic. This would trigger an immediate balance of payments deficit and renewed depreciation of the Cedi.
A reversion to the 10-year mean price of approximately $2,000/ounce represents the existential threat scenario.
New Reserve Value: ~$2.45 Billion.
Direct Valuation Loss: ~$3.05 Billion (a >55% wipeout of reserve value).
Operational Viability: At $2,000/ounce, the GoldBod operational model collapses. The fixed costs of extraction and the premiums paid to miners would likely exceed the international sales price by a massive margin. The “revolving fund” of $279 million allocated to GoldBod would be depleted in weeks as the state attempted to subsidize the purchase price to keep miners selling.
Scenario Gold Price (USD/ounce) Total Reserve Value (USD) Valuation Loss (USD) Impact on BoG
Current Peak $4,500 $5.50 Billion — Stable
30% Correction $3,150 $3.85 Billion ($1.65 Billion) Severe Strain
10-Year Mean $2,000 $2.44 Billion ($3.06 Billion) Insolvency Risk
Analysis: The table demonstrates the extreme sensitivity of the reserves to price corrections. A return to the 10-year average price would effectively wipe out more than half of the value of the gold reserves accumulated, rendering the strategy of “saving in gold” a disastrous capital allocation decision.
This is why the Transparency Deficit is dangerous
With billions of dollars flowing through a new state monopoly, the lack of transparency regarding the beneficial ownership of licensed buying agents creates a high risk of elite capture. The “premiums” paid to aggregators to prevent smuggling could easily morph into a mechanism for political patronage, subsidized by the central bank’s money creation. And the refusal to provide granular detail on trades could result in Ghana sleep-walking into a massive fiscal catastrophe should gold prices ever fall.
GoldBod is currently functioning as a leveraged commodity trading desk operating with a state subsidy. It has replaced the hard discipline of fiscal rectification with the soft cushion of commodity speculation. While this strategy works in a bull market, the sensitivity analysis demonstrates that a reversion to mean prices would render the model insolvent and inflict catastrophic losses on the central bank. The IMF’s warning regarding the $214 million loss is a valid, TRUE, and urgent signal: the cost of Ghana’s gold standard is currently being paid by the degradation of its central bank’s balance sheet.
I accept that all the above make me sound like a Jeremiah screaming in the desert. With many reputable analysts banking on gold prices rallying even further due to uncertainties in the global economy, it is hard to take the idea of major price corrections. Yet, what the recent past has taught us, not least with the 2008 financial crisis and COVID, is that black swans do exist.
In the wisdom of our Ghanaian ancestors, it is always wise to drink water in anticipation of a drought.
Share Us
