Ghana’s commercial banks allegedly facilitated approximately US$20 billion in foreign currency transfers over five years without verifying whether corresponding goods ever entered the country, according to deep-source intelligence reviewed by the Business & Financial Times.
The scale of the compliance failure has shocked financial analysts and raised urgent questions about whether profit motives systematically override regulatory safeguards in Ghana’s banking sector.
Between April 2020 and August 2025, banks reportedly processed more than 525,000 Import Declaration Form transfers worth over GH¢83 billion. Yet only about 10,440 of these IDFs were actually used to import physical goods, meaning less than two percent of all transfers resulted in documented imports. That leaves over GH¢80 billion in foreign exchange outflows unexplained, according to audit data obtained by B&FT.
The revelations come at a particularly sensitive time. Ghana’s cedi lost nearly half its value between 2023 and 2024, precisely when unverified transfers peaked. Financial intelligence sources now link those phantom import transactions directly to forex reserve depletion and currency instability, suggesting the compliance lapses weren’t just paperwork problems but macroeconomic threats.
Here’s how the alleged scheme worked. Bank of Ghana regulations require importers transferring more than US$200,000 to submit supporting documentation proving legitimate imports. Despite this clear threshold, banks reportedly continued processing multiple transfers for the same clients who’d already breached limits, even when red flags appeared obvious. One major bank alone allegedly processed transactions totaling about GH¢3.23 billion across various currencies during the period, while volumes at other institutions ranged down to GH¢87.43 million.
The math gets worse. Analysis showed approximately GH¢127 billion remitted for imports valued at only GH¢51.8 billion, implying nearly GH¢75.5 billion in transfers weren’t supported by corresponding imports. That forty percent under-declaration rate translated into an estimated GH¢22.6 billion loss in customs duties and taxes over five years, effectively making Ghana’s banks unwitting partners in what amounts to industrial-scale revenue evasion.
Banks earn transaction fees and currency spreads on every foreign exchange payment processed, creating what experts call a structural temptation to prioritize volume over verification. When compliance checks slow things down, they may get treated as secondary considerations rather than essential safeguards. Dr. Richmond Atuahene, a banking governance specialist, described the situation bluntly as demonstrating that profit motives now overshadow compliance obligations in Ghana’s financial sector.
The Ghana Association of Banks issued a statement last week attempting to shift responsibility. GAB noted that importers sometimes use one IDF to initiate advance payments, then generate new IDFs when goods arrive to under-invoice and evade customs duties. Since banks don’t control IDF issuance, these activities supposedly occur outside banking system visibility, according to the Association’s October 21 clarification.
But that explanation hasn’t satisfied critics. The systemic nature of the problem suggests more than just clever importers gaming loopholes. Financial intelligence sources told B&FT that some institutions processed over 2,500 transactions during the period, volumes that can’t be fully attributed to importers alone. In some cases, the same IDF number was allegedly reused multiple times for different transfers, or different IDFs paid for the same consignment, classic red flags for both compliance failures and potential money laundering.
The core issue involves disconnected systems. Bank of Ghana, Ghana Revenue Authority, and the Integrated Customs Management System aren’t fully linked, allowing banks to approve forex transfers without automatically verifying that goods arrived or duties were paid. Banks have relied on importers’ declarations without independent confirmation, creating what one audit source called fertile ground for abuse.
Dr. Atuahene recalled how the process used to work. Before transfers were approved, banks verified pro forma invoices, bills of lading, certificates of shipment, and about twelve other documents. Today, that control is gone. Funds now transfer without evidence of goods arriving, transforming what should be trade finance into essentially unmonitored capital flight.
The transfers were heavily concentrated in major currencies, with eighty-five percent in U.S. dollars. Euros and pounds sterling together accounted for more than ninety-seven percent of all transactions without confirmed imports. Registered companies represented fifty-six percent of remitters with transfers totaling GH¢17.3 billion, while registered enterprises and sole proprietors accounted for forty-four percent worth roughly GH¢13.6 billion. Less than one percent involved foreign missions, diplomats or multilateral agencies.
Government insiders have told B&FT that authorities are considering a complete overhaul of the IDF framework. Proposed reforms include linking every forex transfer directly to an import entry in ICUMS and enforcing automatic reporting to Bank of Ghana when thresholds are breached. Whether these changes happen quickly enough to prevent further hemorrhaging of foreign exchange reserves remains the critical question.
GAB has formed a consultative committee with Bank of Ghana, GRA, and ICUMS to review the IDF process and close loopholes. The Association claims banks have substantially completed their assigned tasks, though further engagements with GRA and ICUMS remain ongoing. Meanwhile, the same banks continue processing foreign currency transfers under essentially the same disconnected systems that allegedly enabled twenty billion dollars to disappear without corresponding imports.
For Ghana’s economy, the implications extend beyond lost revenue. These unverified transfers directly inflate demand for foreign exchange, distorting markets and pressuring the cedi. When billions leave the system without corresponding imports, it undermines both currency stability and revenue collection simultaneously. The audit data suggests Ghana’s banks may have inadvertently functioned as the weak link in the country’s anti-money laundering framework, despite extensive training of executives and directors since the Money Laundering Act passed in 2008.
The question now is whether regulatory authorities will impose meaningful consequences or if this becomes another compliance scandal that generates headlines but changes little. With approximately 17,771 IDF applications involved in transfers exceeding regulatory thresholds, there’s substantial evidence for systemic enforcement action if regulators choose to pursue it.
