Ghana - Threat Assessment - 2020 Page 1 of 34 and a “CC” response. US Trafficking in Persons � - Tier 2 rating.

Section 1 - Executive Summary Sanctions & Terrorism: There are no sanctions against the country. Ghana is a Tier 2 Grey Lists: Ghana is listed by FATF & has been (Moderate threat), PPI 2019 (Proliferation) added to the EU list (which came into force on Index country with a “Moderate” response 1/10/20) based on identified strategic AML/ score of 518/1,300. Ghana has a “Very Low” CTF issues. Ghana is listed by the US as a impact score (1.559/10) in the Global “Country of Primary Concern” in respect of ML Terrorism Index 2019. Ghana isn’t included in & FC. US Country Reports on Terrorism.

NRA: Ghana published its first National Risk Response & Resilience: FATF MER 4th round Assessment (NRA) in 2016. The assessment results by GIABA scored Ghana at 73/100 for rated stealing, drug trafficking, , and technical compliance (40 Recommendations), tax evasion as “High”, with fraud at “Medium & 18/100 for effectiveness (11 Outcomes). High” and human trafficking and people Ghana scored 5.46/10 for resilience (Low), smuggling at “Medium” with environmental ranked 10/54 in Africa in the OC Index. crime & cybercrime highlighted too. The overall threat was rated as “Medium High.” Indices: Ghana scored 82/100 and was rated “free” in the 2019 Freedom in the World Organised Crime: According to the OC Index, report, and 59.4/100 for economic freedom Low Criminality - High Resilience. Criminality (Heritage Foundation) described as “mostly 4.89/10, (ranked 26th of 54 African countries). unfree”. The Mo Ibrahim Index of African Main markets are illegal mining (7.5/10), Governance (IIAG) scored Ghana 6th in Africa cannabis (7/10), heroin (6/10), cocaine (5.5/10) at 68.1/100. The Basel AML Index 2019 ranked and synthetics (5.5/10). The main “Criminal Ghana with a score of 5.24/10. Actors” are “State Embedded Actors” (6.5/10), “Criminal Networks’ (6/10), “Foreign Overall Ratings: Ghana is rated the 10th best Actors”(5/10) and “Mafia Style Groups”(1/10). rated country in SSA (out of 40) and 2/14 in , with an overall score of 55/100 Corruption: TI CPI - 2019 - ranked 80/198, “Moderate” risk, 59/100 “Moderate” level for with a score of 41/100, a deterioration from Threats and 50/100 “Moderate-High” level for 2016, where Ghana had a score of 43/100. Responses, with an “Improving” trend.

Modern Slavery: The 2018 GSI Index - 38/51 FCN Rating:”Moderate” Risk 55/100 African countries, with 133,000 modern day “Improving” slaves, and an incidence of 4.8/1000 people

Ghana - Threat Assessment - 2020 Page 2 of 34 Section 2 - Country Dashboard

Ghana ↗ Improving Capital & Population: Accra / 29.8 million approx Political Leader: Nana Akufo-Addo, (since 2017) GDP: USD47.02 billion (2.9% of the SSA economy) Economic Sector Breakdown: Agri (18.3%), Ind (24.5%), Services (57.2%). Exports: Oil, gold, cocoa, timber, tuna, aluminium and diamonds to India (23.8%), UAE (13.4%), China (10.8%), Switzerland (10.1%), Vietnam (5.2%) & Burkina Faso (4%) - 2017. Imports: Capital equipment, refined petroleum and foodstuffs from China (16.8%), US (8%), UK (6.2%), Belgium (5.9%) & India (4.1%) - 2017.

Score: 55/100 “Moderate” FCN Risk Rating (Average Country Score is 43 - SSA) Proceeds / Laundering Rank: 10/40 SSA - 2/14 Region WA range 6.5% - 9.5% GDP / 60-70% of Proceeds

Organised Crime Costs of Corruption range up to approx 26 - 28% of Proceeds range up to approx 5 - 10% of Proceeds (State Embedded 6.5/10, Criminal Actors 6/10, Foreign Networks 5/10 & Mafia Style 1/10)

Ghana Higher (Inherent) Risk Factors Total Criminal Proceeds in Sub Saharan Africa in US$ Billions - FCN Customer Sector Geography 2020 (not including fraud and Risks Risks Risks corruption and tax evasion) Customers with elevated Banking, Other FI’s & DNFPBs - Major export / import partner exposures to criminal activities Medium Risk countries (trade mispricing via such as: IFFs). drug trafficking, theft & Casinos, Real Estate Developers Near neighbour countries, corruption - High Risk / Agents, None Profit including Burkina Faso & Togo Mining Fishing Organisations - Very High Risk & Ivory Coast (OC, Smuggling). 10 2.5 to Fraud - Medium Risk Afghanistan Pakistan, SE Asia Wildlife Dealers in Precious Metals & and Western Europe, as source 2 Goods Piracy to Human Trafficking, Migrant Stones, Car Dealers - High Risk and destination countries & 9 Smuggling & Robbery - Low South America (cocaine). Risk Lawyers, Notaries & Accountants, Trust & Company China, Bangladesh, Thailand & Logging to Higher Risk Sectors and/or Service Providers - Medium Risk West African (inbound HT) & 12.5 Middke East, Europe including Geography Risks Modern Slavery & Germany (Source & Transit outbound HT) 8.3

In Ghana - Greater Accra Drugs Region, Ashanti Region and the 3 Western Region for ML / the Theft three Regions in the north and 15 Greater Accra Region for terrorist activities and financing.

FCN SSA Country Risk Rating - “Moderate” Threats -

GTI GSI INCSR TI CPI US TIP Overall WEF OC US Terror GFI IFF’s IUUF Index OC Index US END Wildlife FCN SSA Country Risk Rating - “Mod - High” Response -

NRA Freedom OC Index FATF 40 FATF 11 Overall Governance GSI - Slavery Proliferation Seizures US$ FATF/EU Lists Basel AML Index

Ghana - Threat Assessment - 2020 Page 3 of 34 Section 3 - Country Information

People & Geography: Ghana is located in economy is made up of agriculture 18.3%, West Africa, in the centre of the Gulf of Guinea industry 24.5%, services 57.2%. These sectors and borders with the Ivory Coast, Burkina Faso encompass the mining, lumbering, light and Togo. Ghana is geographically closer to manufacturing, aluminium smelting, food the ‘centre’ of the earth than any other country processing (cocoa, rice, peanuts, corn, (closets to 0 degree longitude & 0 degree bananas) as well as financial services, latitude) and as such experiences a tropical information and communications technology, climate. Ghana is a beautiful country, endowed education, hospitality and property with natural resources. It encompasses plains, development. Ghana exports oil, gold, cocoa, coastal shrub lands, beaches, forests, waterfalls timber, tuna, aluminium and diamonds to India and lakes (it’s most famous being Lake Volta - (23.8%), UAE (13.4%), China (10.8%), the largest artificial lake in the world). Ghana’s Switzerland (10.1%), Vietnam (5.2%) & Burkina capital, Accra, is the most densely populated Faso (4%) - 2017. The country imports capital city in Ghana, and serves as the administrative, equipment, refined petroleum and foodstuffs economic, legislative and judicial centre for the from China (16.8%), US (8%), UK (6.2%), country. Of it's 29.8 million population, Ghana Belgium (5.9%) & India (4.1%) - 2017. counts some 466,800 migrants for 2019, and 970,600 emigrants. Environment: According to the Environmental Performance Index, Ghana is ranked 124/180 Recent History & Leadership: Formerly countries, with a score of 49.66/100. known as the Gold Coast Ghana was the first country in Sub-Saharan Africa to break away Tourism: Travel & tourism contributed from colonial rule, gaining independence from GHC17,497.3 million (US$3,305.1 million) in the UK in 1957 with as it’s 2019, which represents 5% of the GDP of first president. The period from 1960 onwards Ghana. The labour force for this sector is more was marked by various military coups, than 623,100 people in direct employment, economic stagnation and unstable which represents 5.2% of the total governments. From 2000, the government employment rate in country. Some of the main took positive steps to aid economic prosperity tourist sites include , Kakum - such as the merging of two gold mining firms National Park and Lake Volta. in 2003, and investing in the oil industry in 2007. In 2011, became Finance: In terms of remittances, the country president, representing the National has estimated inflows of US$3.521 billion Democratic Congress party and was (5.2% of the GDP) for the year 2019 and succeeded by in 2012. Mahama according to the World Bank. Connectivity- was eventually replaced in 2017 by Nana wise, there is an internet penetration rate of Akufo-Addo, who is the current president. 48% and 39.97 million mobile connections for the year 2020. With regard to access to the Economy & Trade: In 2017, the GDP was banking system, 42% of the population (over USD47.02 billion, which represents 2.9% of the 15 years of age) hold bank accounts, 5.8% SSA economy. The government revenues have a credit card, and 39% have a mobile amount to USD 9.544 billion. The GDP per money account (2020). capita in 2017 was USD4,700. Ghana’s

Ghana - Threat Assessment - 2020 Page 4 of 34 Ghana - Threat Assessment - 2020 Page 5 of 34 4 - Country Ratings

Available information from leading sources produce over 60 ratings for Ghana, covering both threats and responses in fighting financial crime, sanctions, proliferation finance and terrorism & terrorism finance.

Source Ghana � Source Ghana � Source Ghana �

World Economic Forum 59.7 / 100 Transparency International (TI) 41/ 100 Proliferation Index - PPI Tier 2 Organised Crime Index (84/140) Corruption Perceptions Index (80/198) Threat Moderate Threat Level

OC Index 4.89/10 TI & Afrobarometer 33% Proliferation Index - PPI 518/1300 Criminaility Citizens Views and Experiences of Corruption Overall Rate Controls Controls score Report

OC Index 4.63/10 TRACE 48 Global Terrorism Index 1.559/10 Criminal Actors Bribery Risk Matrix (80/200) GTI - Impact “Very Low” Impact

OC Index 6.5/10 4.8/1,000 US Dept of State Not Included State Embedded Actors Global Slavery Index Incidence of human trafficking Country Reports on Terrorism GSI Incidence

OC Index 6.0/10 Global Slavery Index 133,000 Global Cybersecurity Index 0.437/10 Criminal Networks No of estimated Modern Day Slaves Estimated numbers of modern day 2018 (89/175) slaves

OC Index 5.0/10 Global Slavery Index “CC” Rating Mo Ibrahim Governance Index 68.1/100 Foreign Actors Country Response Rating (Ratings: AAA, AA, A etc) (49.9 - All Africa) (Increasing improvement) (6/54)

OC Index 1.0/10 US Dept of Labor 1,721,914 - 24.7% of children aged Freedom House 82/100 Mafia Style Gangs Child Labour between 5 -14 working Freedom Index “Free”

OC Index Cannabis 7/10 & Heroin 6/10 US Dept of State Tier 2 Rated Heritage Foundation 59.4/100 Drugs Trafficking Synthetic’s 5.5/10 & Cocaine 5.5/10 Trafficking in Persons Economic Freedom Index “Mostly unfree”

OC Index 3/10 IOM Migration I -466,800/E - 970,600 Basel AML Index 5.24/10 Arms Trafficking E - Emigration / I - Immigration (60/125)

OC Index 4.5/10 Illegal Unreported and Unregulated 1.98/5 FIU Egmont Yes People Smuggling (IUU) - IUU Fishing Index (133/152) Member

OC Index 4/10 EU Listing of Countries for Illegal No Interpol Yes Human Trafficking Fishing Member

OC Index 4.5/10 US DoS - Wildlife Trafficking Not Included Asset Confiscations No Illegal Timber Focus / Countries of Concern over 1% of Proceeds

OC Index 4/10 Environment Performance Index 49.66/100 Country National Risk Assessment Yes Illegal Wildlife 124/180

OC Index 7.5/10 EUIPO & OECD Counterfeit Goods 0.157 Financial Information Sharing No Illegal Mining Propensity of Exports (2016) Partnership

OC Index 5.46/10 Tax Justice Network 52 US Dept of State Yes Resilience Financial Secrecy Index (117/133) INCSR Vol I & Vol II

OC Index 6/10 EU List of None Co operative Not Included European Union List Yes AML Jurisdictions for Tax purposes (Comes into force on 1/10/20)

OC Index 6/10 Partially Compliant FATF Standards 73/100 OECD - Global Forum Law Enforcement on Transparency & Exchange Info for Tax Purposes 40 Recommendations

OC Index 6/10 Global Financial Integrity US$2.2 billion - 29.27% (2017) FATF Standards 18/100 International Co- operation Illicit Financial Flows 11 IO’s on Effectiveness

OC Index 6.5/10 Embassy’s from N Korea, Syria, Iran Cuba FATF Standards 73/100 Economic Regulatory Environment or Cuba Core 10 Recommendations

Illegal Drug Dependency / Disorders 184,002/0.63% Embargoes - Country Sanctions None FATF Standards 17/100 Number/Share (Comprehensive - UN, US, EU, UK) Core 4 IO’s on Effectiveness

Numbeo Crime Survey 2020 48.97/100 OFAC Listed Parties 2 FATF Yes (45/129) with Local Addresses Counter - Measures (Strategic Deficiencies) Strategic Deficiencies List

Ghana - Threat Assessment - 2020 Page 6 of 34 Section 4 Continued - Country Threats Heat Map

There are many threats that effect Ghana, which are in most part targeted towards its resources, be they its natural resources, the people, its forests, metals, minerals, seas and wildlife. The effect of corruption increases the threats and reduces the ability to effectively respond. For more details in summary form see the figure below.

Ghana - Threat Assessment - 2020 Page 7 of 34 Section 5 - Key Threats in Detail

In this Section 5, the most important criminal compliance with international AML/CFT markets, are assessed and summarised based standards, and there are no known refusals to on available sources. cooperate with the United States or other governments on money laundering issues”2. 5.1 National Risk Assessment (NRA): Ghana published its first National Risk Assessment Ghana is listed (NRA) in 2016. The assessment rated stealing, US INCSR 2019 drug trafficking, corruption, and tax evasion as 5.3 Corruption: Corruption is not only a “High”, with fraud at “Medium High” and significant generator of illicit funds, but also an human trafficking and people smuggling at enabler of other serious crimes which protects “Medium” with environmental crime & those involved from investigation, prosecution cybercrime highlighted too. The overall threat and/or conviction. was rated as “Medium High.”

The 2019 Transparency International (TI) High Medium High Medium Threats Threats Threats Corruption Perceptions Index (CPI) ranks

Corruption Fraud Human Ghana as 80 out of 198 countries, with a score Trafficking of 41 out of 1003. This is a decline from from Drug Trafficking Migrant Smuggling the score of 48/100 in 2014 and from 43/100 4 Tax Crimes Robbery in 2016 . Scores are from zero (highly corrupt)

Theft to 100 (very clean).

Ghana National AML Risk Assessment - 2016

TI - Corruption Perceptions Index - � 5.2 US INCSR: Ghana is listed in Volume 1 and (Scores out of 100 - higher scores are better) in Volume 2 as one of 80 countries categorised by the US State Department as a Country/ 48.0 Jurisdiction of Primary Concern in respect of 45.0 43.0 41.0 41.0 Money Laundering and Financial Crimes in its 2019 Report. Ghana is described as a “major 2012 2014 2016 2018 2019 money laundering country” in volume 11. In The 2019 TRACE Bribery Risk Matrix5 ranks Volume 2 highlights much of the progress Ghana as 40 out of 200 surveyed countries, being made by Ghana in the areas of (8/54 in Africa) with an overall risk score of 48. strengthening its strategies and laws, training and awareness, preparing sector guidelines, 33% of Ghanaians using public services and implementing a single national identity paid a bribe TI GCB 2019 card. “Ghana continues to work toward

Ghana - Threat Assessment - 2020 Page 8 of 34 According to TI’s 2019 International's Global Mauritius, Namibia, Rwanda, Senegal & Corruption Barometer (GCB) survey of People Seychelles. and Corruption: Citizen's Voices from Around Low Criminality - High Resilience the World6: Africa’s OC Index 2019

• 33% of Ghanian’s using public services paid In terms of criminality, the OC Index ranks a bribe in the previous 12 months, down Ghana 26/54 African countries, and 10 among from 36% in 2015. 15 of its West African neighbours, with an overall score of 4.89/10 • 33% of Ghanian’s surveyed think corruption increased in the previous 12 months & 30% According to the African OC Index, illegal think their government is doing a bad job of mining is the most pervasive criminal market in tackling corruption Ghana, scoring 7.5/10, followed by drugs (cannabis 7/10, heroin 6/10 & cocaine 5.5/10), • Overall, the police service is considered the illegal logging 4.5/10 & human smuggling most corrupt institution, with 59% of people 4.5/10, human trafficking 4/10 and the illegal believing that most, or all police are corrupt, wildlife trade 4/10. with 34% of the respondents using police services reported having paid a bribe to the OC Index Criminal Markets - Importance - � police, down from 58% in 2015. (Scores out of 10 - lower scores are better)

• Ghanian’s also think that the bribery rate 7.5 7.0 (bribe paid in the last 12 months) is high for 6.0 5.5 4.0 4.0 4.5 4.5 Public schools (15%), IDs (33%), Public Clinics

Heroin Wildlife HT Mining Logging Synthetics Cannabis People Smugg & Health Centres (12%), Utilities (23%). The OC Index states that the “State-embedded

TI & Afrobarometer Findings 2019 (% Survey) - � actors, with a score of 6.5/10, are the most (Scores out of 10 - lower scores are better) influential actors in the country. Many politicians are believed to profit from the drugs

59.0 trade and a property boom is widely

33.0 30.0 33.0 recognised to be funded by drug money among the elite. The infiltration of drug money ”Increasing” ”Doing Badly” ”Paid Bribe” ”Most Corrupt - Police” into the ruling New Patriotic Party is extremely 5.4 Organised Crime: According to the likely and has been alleged by domestic senior Organised Crime (OC) Index 2019, Ghana is police officers, those working in national crime rated as Low Criminality and High agencies and of international NGOs in the Resilience, alongside other Sub-Saharan region. This is believed to affect the legislative countries such as Botswana, Ethiopia, process in certain areas; for example, with regards to illicit financial flows.” After State

Ghana - Threat Assessment - 2020 Page 9 of 34 Embedded Actors, the most important criminal capital Accra – and are known to import and/or actor types are “Criminal Networks” at 6/10, produce meth in Ghana. South American “Foreign Actors” at 5/10 and “Mafia Style cartels are known to be involved in shipping Groups” at 1/10. The OCI states that, “the cocaine to Ghana, but do not operate within influence of criminal networks on society is also the country, notwithstanding their strong links significant, operating across drug and human to domestic networks.” smuggling markets. Criminal networks link sea According to the World Economic Forum’s borders in the south, with airports and the Organised Crime Index 20197, Ghana is northern land borders, sometimes using ranked 84/140 scoring 59.7/100. The index internal waterways to Burkina Faso and Nigeria. identifies whether and to what extent Several informal networks operate at national organised crime impose costs on businesses level, bound by ethnic, religious, family and (with higher scores = better scores). other ties; and drugs kingpins are known to influence the outcome of democratic elections. 5.5 Green Crimes: Ghana is home to 221 Given the levels of penetration by these groups amphibian and reptile species, 748 bird into official and recognised groups, it is species, 225 mammalian species, 347 marine sometimes difficult to separate them. The fish species & 157 freshwater fish species. Of mixing of criminal with legitimate networks is a these, an estimated 52% are considered common occurrence. Levels of violence, critically threatened and vulnerable, with however, appear to be low in general.” declines in 41 wildlife species in protected areas by 76% since 19708. OC Index - Criminal Actor Types - Importance - � (Scores out of 10 - lower scores are better) 5.5.1 Environmental “Green” Crimes: Illegal Wildlife Crimes: In recent years, several tons of illegal wildlife or wildlife products have 6.0 6.5 5.0 been seized around the world, with many 1.0

Criminal Networks State Embedded Foreign Actors Mafia Style traced to Africa and, increasingly, West Africa. In 2019 alone, 67.6 tons of pangolin scale As far as Foreign Actors are concerned, these, seizures were from Africa. Ghana is no “operate primarily in the drugs and non- exception to this illegal trade. In 2017, 700kg renewables markets. Asian criminal actors in of pangolin scales, the equivalent of over Ghana are known to have heavily infiltrated 1,600 individual pangolins, were seized in galamsey (illicit gold mining) operations and Malaysia and found to have been shipped have substantial economic power over the through Ghana, despite Ghanaian law market. Neighbouring West African organised protecting pangolins, making any such trade crime groups are known to operate in drug illegal9. markets, particularly in the south – largely in the

Ghana - Threat Assessment - 2020 Page 10 of 34 The country is increasingly becoming a transit selling centres) who patronise bushmeat due hub for the illegal trade in endangered wildlife to the high interest in the delicacy across the like pangolins and some species of snakes country. because of its porous borders. 5.5.2 Environmental “Green” Crimes: Illegal According to African Leadership University Fishing: With 550 km of coastline, fishing in School of Wildlife Conservation10, bushmeat Ghana’s waters supports 124,000 fishers hunting in Ghana has been one of the major producing 254,000 MT annually (70% of total causes of biodiversity loss causing serious catch). Fisheries employ more than150,000 declines in several species of wildlife. people and directly support livelihoods of According to the Forestry Commission (2014), approximately 10% of the population or 3.1 an estimated 380,000 tonnes of bushmeat are million people, most of them living along the consumed annually with a value of about coastline. Fishing generates about US$1 billion US$350 million11. in revenue each year. In 2019, fisheries contributed 0.9-1.1 % of total GDP, a decline 380,000 tonnes of bushmeat are from 4.5% in 2011. At the same time US$60 consumed annually million is estimated as lost annually to illegal, Forestry Commission - 2014 unregulated, and unreported fishing12. This contributes about 0.53 % of GDP. Over 60% of bushmeat is sold in urban markets, with US$60 million is estimated as lost consumption peaking during holidays and annually to illegal, unregulated and festivals. Key species hunted include antelope, unreported fishing African Leadership University School of Wildlife grasscutters (cane rats), rats, pangolins, a wide Conservation - 2020 range of primates, etc. The grasscutter (cane Ghana scores 1.98/5 in the IUU Fishing Index, rat) remains the most popular, and most with illegal fishing in Ghanian waters recently common bushmeat species exploited, with highlighted and condemned as “destructive rodents, such as the giant rat, which in the past industrial fishing practices condemned as hardly appeared on the markets, currently ‘corporate, organised crime13.” The illegal having a significant market share. fishing by foreign trawlers is decimating Whilst bushmeat hunting is permitted through Ghana’s fish populations and costing the licensing, there is weak enforcement of country’s economy tens of millions of dollars a regulations, and as a result, the bushmeat year, according to the Environmental Justice trade is largely unregulated by both state and Foundation14 (EJF). The EJF claims that the local institutions. It is estimated that about practice of “saiko” fishing, is when trawlers 300,000 self-employed hunters are engaged in target the staple catch of Ghanaian canoe bushmeat hunting at the local level. There are fishers, and then sell it back to fishing thousands of “chop bar” keepers (local food

Ghana - Threat Assessment - 2020 Page 11 of 34 communities at a profit. The practice is hunting which all put pressure on native precipitating the collapse of Ghana’s staple species of various habitats in Ghana’s once- fish stock – such as small pelagic fish like expansive rainforest. sardinella, a crucial protein in the local diet. 5.5.4 Environmental “Green” Crimes: Illegal Scientists have warned that stocks could be Mining: According to the NRA, “Ghana’s rich completely destroyed as early as 2020, extractive industries are a target for offences according to EJF. They also highlight that more such as illegal small scale gold mining than 90% of Ghana’s industrial trawl fleet is (“galamsey”) and illegal oil bunkering. The linked to Chinese owners, who depend on latest threats include politically exposed Ghanaian “front” companies to bypass national persons (PEPs), such as government officials laws forbidding their operation, with an who have been involved in the smuggling of estimated 40% of the total catch thought to be cash associated with the above mentioned from illegal fishing. crimes from developing countries to 5.5.3 Environmental “Green” Crimes: Illegal destinations such as the UK, UAE and US.” Logging: Whilst It is estimated15 (by Chatham According to the OCI, “Ghana is one of the House), that around 30% of the worlds timber biggest sources of illicit gold on the African production (from 9 main tropical forest continent. Exports far exceed local production producer countries) is illicit and that nearly and the country is known as a magnet for 10% of imports into consumer countries are smuggled gold from Mali and Burkina Faso, from illegal sources. In some tropical forest and a major supplier of gold dore (semi-pure countries illicit production reaches levels of gold) to refineries in India and the UAE. 50-90%. For example, Chatham House Artisanal and small-scale gold mining activities believes that illegal logging is endemic in are banned, but porous borders, lax Ghana, estimating that 70% is illegal. The implementation of export processes, more largest 3 countries importing logging from preferable tax rates and corruption all facilitate Ghana are India, China & the US. the illicit movement of precious metals and According to Global Forest Watch16, Ghana stones. The illegal mining industry has a saw an alarming 60% decrease in primary significant environmental impact, particularly rainforest in 2018. This was the highest because of mercury contamination of soil and percentage of rainforest loss of any tropical rivers. Fuel/ oil smuggling is also believed to country. Numerous factors contributed to be a significant cost to the government in lost environmental damage in Ghana, including revenue and Ghana is alleged to be a Illegal small scale mining (which causes a transhipment hub for laundering stolen oil.” massive amount of deforestation), rampant 5.5.5 Environmental “Green” Crimes: Illegal land clearing for timber exportation, and Waste Dumping: According to the NRA,

Ghana - Threat Assessment - 2020 Page 12 of 34 “possible money laundering threats specific to As far as Heroin is concerned, the OC Index Ghana include the illicit trade in hazardous scores the trade at 6/10, and states that waste. A recent report called “Waste Crime: “Ghana is a major transhipment point for Tackling Britain’s Dirty Secret” has highlighted heroin and cocaine. Heroin is mostly how organised gangs use bribery and violence transhipped through Ghana, from Afghanistan to obtain council contracts to clear waste, but to Europe and Asia, but domestic consumption end up sending the hazardous waste to Africa of the drug is growing. Similarly, Ghanaian and for that matter Ghana. They also found that organised criminal groups have been central in these criminals were also linked to a raft of the globalisation of the illicit cocaine trade. illegal activities including human trafficking, Their global networking has allowed Ghana to fraud, drugs firearms and money laundering.” become a central trafficking hub, linking global markets for illicit drugs. Ghanaian networks are 5.6 Drug Trafficking: Ghana has an estimated linked to major continental drug trafficking 184,002 people17 with illegal drug use nodes and facilitate the overland, air and sea disorders (2017), representing 0.63% of the transport of large volumes of heroin from east population. to west.” Ghana is one of the largest cultivators in The use of synthetic drugs is growing fast, with West Africa of cannabis” and “is a major the OC index reporting that synthetics such as transhipment point for heroin and “tramadol and fentanyl, growing rapidly in cocaine. OC Index - 2019 Ghana. Tramadol is largely imported from India and has become a subject of interest since The OC Index 2019 reports that “Ghana is one 2016. Its use is linked to increased levels of of the largest cultivators in West Africa of everyday violence, including armed robbery cannabis” and “is a major transhipment point and youth vandalism, and car accidents. for heroin and cocaine.” Fentanyl is making a gradual entry into Ghana,

Cannabis is rated as 7/10 and according to the with concerns about its usage and effect. OCI is “one of the most – if not the most – Methamphetamine ('meth') is known to transit widely consumed drugs in the country. from Nigeria, and meth labs are believed to Cannabis is perceived as an ‘indigenous’ drug operate in Ghana, though none have been and therefore seen in communities as less found yet. Precursor chemicals are also thought harmful. The most at-risk populations are to transit through the country.” between 15 and 35 years old, particularly There were a total of 2,559 Drug trafficking students. Ghana is currently considering a new cases occurring in the assessment period. law to decriminalise drug possession and use, There was no information on usage of narcotic which has further spurred the growth and use of cannabis.”

Ghana - Threat Assessment - 2020 Page 13 of 34 drugs within the country. Narcotic drugs related Current harsh economic conditions have arrests involved cocaine, heroin and marijuana. encouraged some farmers to go into marijuana cultivation. Most reported cases emanated Heroin, like cocaine comes to Ghana from Latin mostly from the Volta and Brong Ahafo Regions America and it is then taken to Europe and of Ghana. Cases involving marijuana were also America by couriers and through other found to be higher than cases relating to other means.4 narcotic drugs.”

OC Index - Drug Trafficking - Importance - � (Scores out of 10 - lower scores are better) 5.7 Modern Slavery/ Human Trafficking: According to the 2018 GSI Index18, Ghana is ranked 38/51 African countries, with 133,000 7.0 5.5 5.5 6.0 modern day slaves, and an incidence of 4.8/1000 people with a “CC” Government Cocaine Synthetics Cannabis Heroin response19. Marijuana cultivation is rife throughout the Children in Ghana engage in the worst country, especially along the forest belt. forms of child labor, including in fishing Current harsh economic conditions have and cocoa harvesting, sometimes as a encouraged some farmers to go into marijuana result of human trafficking. cultivation. Most reported cases emanated US Labour Dept - 2019 mostly from the Volta and Brong Ahafo Regions Children in Ghana engage in the worst forms of Ghana. Cases involving marijuana were also of child labor, including in fishing and cocoa found to be higher than cases relating to other harvesting, sometimes as a result of human narcotic drugs. trafficking. According to the US Department of According to the NRA, “available information Labour, 1,721,914 - 24.7% of children aged showed Ghana as a transit point in the drug between 5 -14 are working. trade with inflows of cocaine from Latin According to the NRA, “with respect to the America. According to The National Integrated inward flow, nationals from foreign Programme Report (2012- 2016.) Ghana was a jurisdictions, such as China, Bangladesh, major hub for cocaine coming from the Bight of Thailand and the West African sub region, were Benin through Togo and Nigeria with the procured into the country by human traffickers. second route passing through Guinea. Domestic cases of human trafficking were Heroin, like cocaine comes to Ghana from Latin reported to be rife. Most of the victims were America and it is then taken to Europe and children recruited to work on farms, and for America by couriers and through other fishing activities, and for illegal mining means.Marijuana cultivation is rife throughout (galamsey) activities.” the country, especially along the forest belt.

Ghana - Threat Assessment - 2020 Page 14 of 34 Ghana - Threat Assessment - 2020 Page 15 of 34 In the US Trafficking in Persons (TIP) 201920 & in inland fishing and forced labor in domestic 202021 reports, Ghana is listed as a Tier 2 work. Organised traffickers who target country. vulnerable parents and communities facilitate child trafficking in the fishing industry in Ghana Tier 2 rated Country and other West African countries. Relatives US TIP - 2020 often send girls via middlemen to work in harsh The 2020 Report states that, “human traffickers conditions in forced labor in domestic work. exploit domestic and foreign victims in Ghana, Children in northern whose and traffickers exploit victims from Ghana parents use middlemen or relatives to send abroad. Traffickers subject Ghanaian boys and them to work in agriculture in the south during girls to forced labor within the country in inland school breaks or the dry season are at and coastal fishing, domestic service, street increased risk for forced labor. Ghanaian girls hawking, begging, portering, artisanal gold and young women from northern regions move mining, quarrying, herding, and agriculture, to urban centres throughout Ghana to seek including cocoa, which represents one-quarter work as porters; they are at risk for sex of the child labor in Ghana. Donor-funded trafficking and forced labor. Ghanaian children research focused on the fishing industry on who do not have access to school or who can Lake Volta indicated that more than half of the attend only intermittently due to limited space children working on and around the lake were and the double track school schedule are at born in other communities and that many of risk for sex and labor trafficking. Traffickers these children are victims of forced labor, not subject Ghanaian girls, and to a lesser extent allowed to attend school, given inadequate boys, to sex trafficking in urban areas across housing and clothing, and controlled by Ghana. Some Ghanaian girls are forced into fishermen through intimidation, violence, and labor as part of a ritual to atone for sins of a limited access to food. Traffickers force boys as family member. young as five years old to work in hazardous conditions, including deep diving, and many Ghanaian women and children are recruited suffer waterborne infections. Girls perform and sent to the Middle East and Europe, or to work on shore such as cooking, cleaning fish, other parts of West Africa, for forced labor and and preparing fish for market, and are sex trafficking. NGOs report the use of internet vulnerable to sexual abuse and forced platforms to recruit Ghanaians seeking work marriage for the purpose of exploitation. A overseas. Donor-funded research in 2018 study of the prevalence of child trafficking in indicates that the vast majority of Ghanaian selected communities in the Volta and Central migrants recruited by registered and Regions indicated that traffickers had subjected unregistered agencies or agents for children from nearly one-third of the 1,621 employment in the Middle East are female households surveyed to forced labor, primarily domestic workers, aged 20 to 34 years with at

Ghana - Threat Assessment - 2020 Page 16 of 34 least a junior high education, who migrated for 5.8 in the Cocoa Industry: better job opportunities. Most recruiters or According to the Global Slavery Index22. intermediaries used informal procedures with Ghana, along with neighbour Ivory Coast, are contracts that lacked worker protections; some the world’s two largest cocoa producers, with contracts contained false or little information, their combined production contributing 60% and some were verbal. Nearly all the Ghanaian of the world’s annual supply of cocoa. Whilst domestic workers were employed by families an estimated 1.1 million adults worked in and most reported the work experience did not cocoa agriculture in the medium and high match the promises; their passports were cocoa growing areas of Ghana between seized at arrival; and the experience was August 2016 and August 2017, 3,700 adult abusive. Abuses included threats, sexual victims of forced labour in cocoa agriculture assault, beatings, and denial of food. have been estimated. The estimated figures for Unscrupulous agents arrange transport of child labour are 94% (or 668,000 of the Ghanaians seeking employment in Europe and estimated 708,000) children working in cocoa the Middle East through North Africa, where agriculture in medium and high cocoa traffickers exploit, hold involuntarily, and extort producing areas of Ghana between August funds from the victims. Fraudulent recruiters 2016 and August 2017 (children performing lure Ghanaian men under false pretences to go either hazardous labour in the previous 12 to the Middle East, where traffickers subject months, exceeding maximum allowable them to forced labor and sex trafficking. working hours for children their age in the Traffickers coerce some Ghanaian men and previous week, or both). women into labor and sex trafficking in the United States. traffickers lure Nigerian women 5.9 Tax Evasion: Ghana’s tax revenue to GDP and girls to Ghana with the promise of a good ratio was 14.1% relative to the ‘regional’ job and coerce them into commercial sex to average of 17.2% according to the Revenue pay exorbitant debts for transportation and Statistics in Africa 2019 published by the lodging. Traffickers also coerce some Ghanaian OECD, or 16.3% as reported by the African and Nigerian labor migrants into commercial Union (see Section 8 below). This is in part due sex as the traffickers demand more money for to the size of the shadow economy, which was transit and document costs. Traffickers subject estimated as significant at 39.37% of GDP in children from West African countries to forced 2015, compared to the average of 27.78% labor in Ghana in agriculture, fishing, or from 158 countries23 (but also see Section 7.6 domestic service. Ghana is a transit point for below). West Africans subjected to sex trafficking in Europe, especially Italy and Germany.”

Ghana - Threat Assessment - 2020 Page 17 of 34 Ghana was rated “Partially Compliant” in 2018 According to the 2018 Global Cybersecurity by the OECD in its Global Tax Forum on Index (GCI)26, Ghana scored 0.437/10 and is Transparency & Exchange Information for Tax described as having a “Medium” level of Purposes (after being rated “Largely commitment rated 89th globally out of 175, Compliant” in 2014) and scored 52 “moderate” and 11th out of 44 in Africa in terms of in the Tax Secrecy Network’s Financial Secrecy cybersecurity. Between 2016 and 2018, the Index, ranked 117/133. country was estimated to have lost over US$200 million to recorded cyber crime

5.10 Financial Fraud: In 2019, the banking cases, with more than half (60%) linked to 27 industry reported a total number of 2,295 fraud . These figures included US$35.7 million fraud cases as compared to 2,175 fraud cases in 2016, US$69.2 million in 2017 and US$97 reported in 201824. The Banking Industry million from January to August 2018, with reported approximately GHC115.52 million substantial amounts taken from business and (US$19.6 million) as fraud to the Bank of banks. Ghana. Of the total values reported, Homicide rates at 2.1 per 100,000 UNODC - 2017 approximately GHC 33.44 million (28.96%) (US$5.7 million) was reported as losses 5.12 Other Crimes: According to UNODC28 incurred, whiles approximately GHC 82.06 homicide rates in Ghana for 2017 were 2.1 per million (71.04%) (US$13.95 million) was 100,000 people, with Ghana ranked 48/97 recovered. The various forms of advanced countries, and imprisonment rates were 51 per technologies adopted by financial institutions 100,000 people, and ranked 127/138 have made the banking sector more countries (with 1 being the highest). According susceptible to various risks such as phishing, to the Numbeo 2020 Crime Index, Ghana is identity theft, card skimming, vishing, email internationally ranked 45/129 with a score of fraud and more sophisticated types of cyber- 48.97/10029. Whilst these are much better than crime. Internet Fraud is also on the rise, with so many of its neighbours, economic conditions called “Sakawa boys” generating funds from play a part. For example, youth unemployment international romance or investment scams25. estimated by the ILO in 2019, was at 9.1%30 and this increases the vulnerability of these 5.11 Cybercrime: According to the NRA, young people to social vices such as armed “Cyber- focuses mainly on robbery, drug trafficking and prostitution. advanced fee and romance fraud. However, the scope for more complex cyber fraud is 5.13 FCN Overall Country Threat Ratings: endless.” Ghana is rated the 14/40 in SSA and 3/14 in West Africa, for threats with an overall “Moderate” Threats score of 59/100.

Ghana - Threat Assessment - 2020 Page 18 of 34 Ghana - Threat Assessment - 2020 Page 19 of 34 Section 6 - Sanctions & Terrorism

In this Section 6, the focus is on sanctions and foreign terrorist fighters and Ghana’s proximity terrorism threats. to terrorism-prone countries, such as Nigeria, Cote d’Ivoire, Mali, Niger and Chad potentially 6.1 Sanctions: Ghana is not subject to increases the vulnerability of Ghana to the risk international sanctions. of terrorism and terrorist financing.” The FATF The 2019 Peddling Peril Index31 (PPI), Report also stated that, “although the focussed on proliferation, prepared by the incidence of terrorism and terrorist financing in Institute for Science and International Security, Ghana is low, the TF risk was rated high in the which classifies Ghana as a Tier 2 country, a NRA due to Ghana’s proximity to terrorism- country that does not have “extensive nuclear prone countries including Nigeria, Cote or other sensitive commodity supply d’Ivoire, Mali, Niger and Chad and the capabilities, but nevertheless pose a risk of emergence of ISIS and its campaign via social illicit or unauthorised supply, facilitation, or media.” transfer of such commodities”. Ghana has a According to the Global Terrorism Index34 ”moderate threat level 2”, and a “Moderate” 2019, Ghana is ranked 86th highest out of 138 controls score of 518 out of 1,300 points. countries and scored 1.559/10 based on the Tier 2 Country - Moderate level of impact of terrorism in the country which is controls categorised as “Very Low” impact. PPI - 2019 According to the UK Government Travel Cuba has an embassy in Ghana, but North advice35, “Terrorists are likely to try to carry out Korea, Syria and Iran do not. attacks in Ghana. Attacks could be

There are 2 entries, made up of 1 charity and indiscriminate, including in places visited by one entity listed by US OFAC with addresses in foreigners. Terrorist groups associated with al- Ghana32. Qaida in the Islamic Maghreb (AQIM), Islamic State of Libya and Islamic State West Africa 2 entries on the OFAC list (ISWA) present a threat in the region. These US OFAC 2020 groups have demonstrated capability and 6.2 Terrorism/Extremism: According to the intent by mounting attacks against security FATF 4th MER 201733, “the TF threat in Ghana forces and civilians in several countries, most is generally moderate. Nevertheless, the recently in Burkina Faso and Mali.” country recently experienced a few cases of nationals joining the Islamic State (ISIS) as

Ghana - Threat Assessment - 2020 Page 20 of 34 Section 7 - Money Laundering

In this Section 7, the focus is on Ghana’s According to the NRA, “The prevalence of vulnerability to money laundering. huge cash transactions in the Banking Sector makes the sector vulnerable to the threats of 7.1 Higher Risk Areas: Higher risk areas money laundering as cash transactions do not (including from the NRA) are set out below. In always carry record of actual sources, owner many cases a single risk factor may not be and legitimacy. The improper address system evidence of actual higher risks. also makes it difficult for banks to verify clients’ residence and business addresses as part of Ghana Higher (Inherent) Risk Factors their due diligence.” Customer Sector Geography Risks Risks Risks

Customers with elevated Banking, other FIs & DNFPBs - Major export / import partner The NRA rates Banking & other FIs as Medium exposures to criminal activities Medium Risk countries (trade mispricing via such as: IFFs). risk when it comes to assessing their drug trafficking, theft & Casinos, real estate Near neighbour countries, corruption - High Risk developers / agents, non-profit including Burkina Faso & Togo organisations - Very High Risk & Ivory Coast (OC, smuggling). vulnerabilities, as well as Medium risk overall to fraud - Medium Risk Afghanistan Pakistan, SE Asia Dealers in precious metals & and Western Europe, as source to human trafficking, migrant stones, car dealers - High Risk and destination countries & for DNFPBs (and sectors such as Casinos, Real smuggling & robbery - Low Risk South America (cocaine). Lawyers, notaries & Estate Developers / Agents & None Profit to Higher Risk Sectors and/or accountants, trust & company China, Bangladesh, Thailand & Geography Risks service providers - Medium Risk West African (inbound HT) & Middle East, Europe including Organisations - Very High; Dealers in Precious Italy & Germany (Source & Transit outbound HT) Metals & Stones & Car Dealers - High; and In Ghana - Greater Accra Region, Ashanti Region and the Lawyers, Notaries & Accountants & Trust & Western Region for ML / the three Regions in the north and Greater Accra Region for Company Service Providers - Medium). Low terrorist activities and financing. Ratings were reported for both Insurance & the 7.2 Cash Based Money Laundering: Ghana Securities sector. has seen rapid economic growth since 2010, What makes the Banking Sector vulnerable to with increasing access to formal financial the threats of money laundering and terrorist services available to more than ever before. financing, according to the NRA “are huge However, according to the World Bank36 in cash transactions, inadequate location of 2019, financial access across regions and customers addresses, and the fast growing demographics is still low, particularly among mobile money activities.” women, poor and rural citizens. For example, in 2017, 54% of women had an account with a According to the NRA, “Some of the most formal financial institution, compared to 58% vulnerable products and services of the for the general population and 62% of men. Banking Sector include; Current Account Products, Foreign Exchange Account Products, Whilst many financial transactions are carried Savings Account Products, Trade Finance out via the formal financial sector, substantial Services, Private Banking, Investment Accounts, amounts are still carried out face-to-face, or by and International Money Transfers. using the informal sector.

Ghana - Threat Assessment - 2020 Page 21 of 34 Geographically, the Greater Accra Region, Transaction and Virtual Currency laundering Ashanti Region and the Western Region are are also important methods, however these are considered to be the most vulnerable regions not mentioned in the NRA. to Money Laundering, whereas the three Regions in the north and Greater Accra Region 7.6 The Informal Economy: According to the are considered the most susceptible to terrorist NRA, “the Ghana Statistical Service estimates activities and financing. that 86.1% of all employment in Ghana is found in the informal economy” and “the share of the 7.3 Trade Based Money Laundering: Foreign informal sectors contribution to GDP is 58% in trade represents 71.7% of Ghana GDP in 2018 Ghana.” (World Bank). The country’s main seaport is the Port of Tema, 30 kilometers east of Accra, and Employment in the informal economy handles about 12 million tonnes of cargo a at 86.1% year. Ghana mainly exports ore and gems, Ghana Statistical Service - 2017 cocoa, woods, oil, fish, and horticultural products. Its main clients are India, China, As far as the shadow economy is concerned, South Africa, Switzerland, and the Netherlands. the NRA confirmed that “business operations in The Netherlands is its main client for Ghana are mainly executed by cash horticultural products. The country mainly transactions and records keeping in most imports capital goods, oil, and food products instances are non-existence. Among the small from China (which has been the largest scale private businesses this phenomena is exporter with Ghana in 2013). The other common leading to revenue leakages. There is suppliers are the USA, Belgium, India, and the absence of official protection and recognition United Kingdom. According to GFI, the US$2.2 Unregistered economic activities, non-taxation, billion in illicit financial flows left Ghana in and incapability of public workers to fulfil their 2017 (see Section 8 below). Africa, most likely duty due to lack of recognition by state agents; through trade mis-pricing (See Section 8 Source of capital is personal savings and below). As a result, Ghana is particularly persons who work there are predominance vulnerable to money laundering via trade. self-employed. In spite of efforts by SSNIT to get workers in that sector registered, only 7.5 Other Money Laundering: The Securities minimal results have been achieved. Most sector in Ghana has a Low Risk but a “Medium” workers work for less than the official minimum vulnerability to money laundering, according wage and are unable to contribute to their to the NRA, with AML controls in the sector pension, or save for future investment. This considered to be very low. The institutions that sector is characterised by high dependency on are most vulnerable include fund managers, daily subsistence business as well as small mutual funds, unit trusts and broker-dealers. profit margin.”

Ghana - Threat Assessment - 2020 Page 22 of 34 Section 8 - Illicit Funds including Estimated Criminal Proceeds

In this Section 8, the focus is on Ghana’s The risks increase in trade with so-called vulnerability to Illicit Financial Flows and Illegal advanced economies. Whilst not all IFFs are Proceeds and to the laundering of criminal and made up of criminal activity, a significant other illicit funds. proportion will be.

According to the African Union37 based on According to the sources and analysis carried work and data provided by GFI, it is estimated out in this Threat Assessment, estimates for that Ghana suffered from illicit financial flows criminal proceeds, laundered funds and funds from 2004-2013, averaging US$4,013 million a generated by corruption and organised crime, year, and US$2.2 billion38 in 2017, according to amongst others, are estimated in the following Global Financial Integrity39 ranges: (GFI), to have left the country. Total Criminal Proceeds in Sub Saharan Africa in US$ Billions - FCN •Total estimates for criminal 2020 (not including fraud and Ghana has a Tax to GDP ratio proceeds combined of 6.5 corruption and tax evasion) 40 of 16.3% , which is the 24th to 9.5%68 of GDP and with lowest in Africa, and around 69 Mining Fishing 5 - 10% of this estimated the average African figure of 10 2.5 Wildlife as costs of corruption. 16.2%, and rated across 2 Goods Piracy 9 Africa as a “Medium” Tax Logging •Total estimates for monies Collection Country. 12.5 Modern Slavery available for laundering 8.3 through the formal sector is According to GFI, the most Drugs 3 Theft 70 common method for 15 60 - 70% of criminal transferring illicit financial proceeds and 26 - 28%71 funds, is through trade involving organised crime, mispricing. GFI believe this method or series with most significant criminal actors being of techniques may represent up to 80%41 of “State Embedded Actors”, followed by illicit financial flows, and can involve abusive “Criminal Networks”, “Foreign Actors” and and or aggressive transfer pricing, trade “Mafia Style Groups”. mispricing and mis-invoicing, for example The largest criminal will intentionally overpaying for imports of goods include corruption, drug trafficking, illegal or services (or underpaying for exports or mining, people smuggling, human trafficking, services) is a straightforward way of illegally tax evasion, and those crimes identified as the transferring monies out of a country. largest markets across Sub-Saharan Africa (see Pie Chart above).

Ghana - Threat Assessment - 2020 Page 23 of 34 Section 9 - Resilience & Response

In this Section 9, the focus is on Ghana’s level round results by GIABA, as updated by the of resilience and response. 2018 Report (GIABA upgraded R 16 & R 17 from PC to LC & “welcomed the steps that 9.1 National Risk Assessment: According to Ghana has taken to improve its technical the NRA, Ghana is judged as having a compliance with Recommendations 18, 22, 33 “Medium” Vulnerability because National and 35; however, insufficient progress has Combating ability is “Low - Medium” and been made to justify a re-rating of these Overall Sector Vulnerability is also “Medium”. Recommendations.”). The overall Vulnerability rating is influenced by two factors. Firstly, the national combating Ghana scored 73/100 for technical compliance ability generally rated low medium, as a result (40 Recommendations), & 18/100 for of poor, or ineffective, activities related to effectiveness (11 Outcomes), and 73/100 for investigations and 10 core prosecution, Recommendations & forfeiture and 17/100 for 4 core criminal conviction. Immediate Outcomes. The poor ratings The second factor is originally allocated in the overall sector relation to Immediate vulnerability due to Outcomes vulnerability in subsequently resulted DNFBPs, insurance, in FATF including banking, securities, Ghana on the FATF list financial inclusion, of “Jurisdictions and other financial under Increased services Monitoring” in 9.2 FATF: The 4th mutual evaluation report October 2018. (MER) of Ghana was adopted on May 2017 The latest results are set out below. According and a first follow-up report, which analysed to FATF, “Ghana should continue to work on Ghana’s progress in addressing the technical implementing its action plan to address its compliance deficiencies identified in its MER, strategic deficiencies, including by: (1) was published in June 201842. implementing a comprehensive national AML/ Based on a simple scoring model developed CFT Policy based on the risks identified in the by FCN, applied to the 2017 FATF MER 4th NRA, including measures to mitigate ML/TF

Ghana - Threat Assessment - 2020 Page 24 of 34 risks associated with the legal persons; (2) measures remains weak and a major concern. improving risk-based supervision, by DNFBPs constitute a weak link and the enhancing the capacity of the regulators and significant shortcomings in this sector have the awareness of the private sector; (3) serious implications on the effectiveness of the ensuring the timely access to adequate, implementation of preventive measures and accurate and current basic and beneficial the AML/CFT regime in Ghana.” ownership information; (4) ensuring that the High resilience scores for Ghana FIU is focusing its activities on the risks OCI - 2019 identified in the NRA, and adequately resourced; and (5) applying a risk-based 9.3 Resilience to Organised Crime: In terms approach for monitoring non-profit of “Resilience” to financial crime, Ghana organisations.” scored 5.46/10 (“High Resilience”) and ranks 10/54 African countries, made up of “AML” - Focussing just on core elements of the 40 6/10 for “International Co-operation” - 6/10, for Recommendations (Key Recommendations): “Law Enforcement” - 6/10, and for "Economic R8 (NPOs) - NC, R10 (CDD) - LC, R12 (PEP) - C, & Regulatory Environment” - 6.5/10. R13 (CBR) - C, R14 (MVTS) - C, R15 (NewTech) - C, R22 - (DNFPBs CDD) - LC, R26 (FI According to the African OC Index, “Ghana has Supervision) - LC, R28 (DNFPBs Supervision) - a relatively high score for resilience in PC & R29 (FIU) - C. Taking these core elements, comparison with other African states, ranking FCN scores Ghana at 73%. 10th overall. Most of its resilience scores are between 5 and 6.5, except for support for 43 According to the FATF 4th MER 2017 , victims and witnesses of organised crime and “overall, the banks in Ghana have a good prevention, which score 3.0 and 4.0, understanding of ML/TF risks they face and the respectively. Ghana has been relatively vocal larger banks are strongest in their mitigation on the need to tackle organised crime. efforts. However, there is a significant However, there is very little political appetite to difference in the level of understanding of the actively deal with high levels of criminality in ML/TF risks and application of preventive Ghana. Levels of interest in dealing with the measures between the banks and other challenges posed by the mixing of drug and institutions within the financial sector. More criminal money with legitimate funds are low. robust risk-based AML/CFT controls are needed to ensure that AML/CFT obligations Ghana has a strong anti-corruption legal are being adequately applied across the framework, enhanced by the entry into force, in financial sector,” and the “majority of DNFBPs 2016, of the Public Financial Management Act, do not understand their ML/TF risks and AML/ which contains strict requirements for public CFT obligations. Implementation of preventive procurement. However, significant challenges in enforcement remain. Similarly, a number of

Ghana - Threat Assessment - 2020 Page 25 of 34 anti-corruption bodies have been set up, but 9.6 Governance: The Mo Ibrahim Foundation concerns over their independence and Governance47 2018 scores Ghana at 68.1/100 resourcing arguably call into question their (African average is 49.9) and 6/54 in Africa, efficacy.” with an “Increasing Improvement” trend.

Regarding prevention, Ghana is working with Ghana is rated 6th highest out of 54 international organisations to set up bodies African countries for governance and systems to combat organised crime. The Mo Ibrahim Index - 2019 country also has a number of national policies 9.7 Asset Seizures: According to the FATF 4th to address specific organised crime types; for MER 201748, “Ghana does not proactively example, human trafficking. Nevertheless, the pursue confiscation as a policy objective and implementation of preventive policies and the confiscation statistics do not reflect the plans is patchy. A number of new government assessment of ML/TF risks.” agencies are not fully operational due to under- resourcing. Resources allocated to organised Ghana does not proactively pursue crime prevention activities are extremely confiscation as a policy objective and limited and Ghana relies heavily on external the confiscation statistics do not reflect aid.” the assessment of ML/TF risks FATF 4th MER - 2017 Overall Freedom rating “Free” 9.8 Financial Intelligence Unit: Ghana’s Freedom in the World Index - 2019 Financial Intelligence Centre (FIC) was 9.4 Freedom: Beyond the definitions ascribed established in April 2010, and became an to human trafficking and/or modern slavery, a Egmont member in January 2014. broader concept of freedom is described by 49 Freedom House’s, Freedom in the World Index, According to the FATF 4th MER 2017 , which ranks countries and their citizens as “Ghana has a well functional financial either, “free” “partly free” or “not free.” Ghana intelligence unit (the FIC) which analyses and scored 82/100, and is rated “free44”. disseminates good quality financial intelligence (operational and strategic intelligence) to According to the Heritage Foundation’s 2019 competent authorities, especially the LEAs. The 45 Index of Economic Freedom , Ghana’s intelligence generated are from STRs received economic freedom score is 59.4/100 making and additional information received from its economy one described as “mostly unfree”. financial institutions, administrative and law

9.5 Basel AML Index: According to the enforcement agencies and other sources. The 201946 findings, Ghana scored 5.24/10 in the FIC has analytical and data mining tools but Basel AML Index, rated 60/146 countries. has initiated actions to acquire a more sophisticated analytical tool to enhance its

Ghana - Threat Assessment - 2020 Page 26 of 34 operational efficiency. The weak compliance by In terms of the 2016 183 STRs filed (January to DNFBPs and some non-bank financial June), 36 were disseminated by the FIC to institutions (NBFIs) with their reporting various government agencies, leading to 2 obligation limits the number of STRs available money laundering convictions but no reported to the FIC for its operations,” and “the FIC plays value of confiscated assets. For more details a central role in generating financial see the FIC 2016 Annual Report50. intelligence. The analysis products generated 183 STRs filed, 36 disseminated to LE by the Centre are of good quality and have agencies, 2 ML convictions, and no been used by Law Enforcement Agencies reported asset seizures. (LEAs) to initiate or support investigations, Financial Intelligence Centre - 2016

STRs Filed - FATF 4th MER - 2017 - � . * Jan - June 9.9 Recent Developments: A new Company's Act 2019, (Act 992)51 came into force in August 2019, following a commitment

375.0 356.0 369.0 310.0 by the Ghana government in London at the

183.0 137.0 2016 Summit on Corruption, which includes new provisions on beneficial ownership and 2011 2012 2013 2014 2015 2016* transparency of companies registered in especially in relation to predicate offences. In Ghana. In addition, a central register is being general, financial intelligence and other established which will record “the true and relevant information are available and used by actual owners of companies in a manual and LEAs for financial investigation, including asset electronic format.” tracing in relation to money laundering.”

“However, Ghana should significantly increase the use of financial intelligence to identify ML and TF cases, in accordance with its risk profile and in particular, its TF risk.”

“STRs filed to FIC are mostly by FIs. The bulk of the STRs (at the FIC) are filed by banks , a limited number is filed by NBFIs, insurance and securities operators while only one STR has so far been filed by DNFBP despite the high ML risk that the sector faces.”

Ghana - Threat Assessment - 2020 Page 27 of 34 Section 9 - Resilience & Response Continued

Based on the FCN Sub-Saharan Africa Risk Rating Model, Ghana is rated overall at “Moderate - High” for its response at 50/100. Ranges for individual components are summarised below, with Low Response - RED, Moderate Response - Amber & Higher Response - Green, (see Section 4 for actual ratings). Key component ratings over showing the progress for FATF MER ratings and for OC Index for Resilience, and over time in the Mo Ibrahim African Governance Index and the Basel AML index are also shown.

Ghana - Threat Assessment - 2020 Page 28 of 34 Section 10 - Observations & Recommendations (O&Rs)

Based on this Threat Assessment, the following • Stakeholders should consider how to further O&Rs are made as follows: enhance the response of the private sector, and in so doing, incentivise an improvement Overall O&Rs: in “preventative measures” by moving • The National Ghana AML Risk Assessment beyond current FI / DNFPB assessments published in 2016 should be refreshed. based on technical compliance to one based more broadly on testing effectiveness. • The Ghana Financial Intelligence Centre (FIC) should provide meaningful feedback to O & R for Ghana Financial Institutions: FIs to reporting entities and should consider consider whether their AML/CTF programmes establishing a Ghanaian Financial reflect the threats identified here, &/or if Information Sharing Partnership. changes are needed.

• The action plan agreed with FATF should be O & R for Foreign Financial Institutions: implemented, including making Foreign FIs that have exposure to Ghana from improvements over NPOs & DNFPBs & when outside the country, may want to consider: achieved, the country could be removed • PEPs are likely inherently higher risk, due to from FATF & EU Strategic Deficiencies List. the levels of , and the Actions to improve OECD rating on tax “State Embedded Actor” scores in the OCI, transparency should be completed. therefore FIs should consider undertaking • The agencies responsible for asset recovery EDD+ and heightened monitoring. should target greater asset recoveries than • Ghana can be considered “Moderate”” FC those reported, which represent significantly risk from a foreign FI perspective, relative to less than 1% of estimated criminal proceeds. other countries. • The existence of high level corruption • Following publication of the 2017 MER, all facilitates criminality and as a result, core Recommendations that rated either PC combating corruption remains crucial. The or NC, such as: R8 (NPOs) - NC, R25 (UBOs), country should increase resources to levels R28 (DNFPBs supervision) - NC & R29 (FIU) - commensurate with meeting fighting PC, R33 (statistics) - PC, R35 (sanctions) = OC, financial crime expectations, as well as and R39 (extradition) - PC should be of reviewing current priorities to ensure a focus concern to foreign FIs dealing with Ghanian on main criminal markets and those activities FIs and DNFPBs. that pose the greatest threats and harms, including “green crimes”.

Ghana - Threat Assessment - 2020 Page 29 of 34 Appendix 1 - Range Matrices by FCN

In Section In Section 8, Illicit funds including “Criminal Proceeds”, estimates for criminal funds in percentage terms and for “Costs of Corruption”, as well as estimates for “Laundering” and “Organised Crime” are set out, based on the inputs and calculations explained below.

1. Criminal Proceeds and Corruption: Table A1 below illustrates how the final estimates for “Criminal Proceeds” and “Costs of Corruption” are estimated. By taking the level of “Criminality” in the OC Index 2019, and the score from TI’s Corruption Index 2019, FCN’s overall Country Risk Rating, and based on the aggregate of these 3 sources, a final range estimate for criminal proceeds can be established. For corruption, the three sources are used, but ranges then depend on the level of corruption based on TI’s Corruption Perception Index 2019 score.

Table A1. Range Matrix for Estimating Criminal Proceeds & Corruption by FCN - 2020 - (Very High Rating is 4, High Rating is 3, Moderate Rating is 2 & Low Rating is 1 - with all scores aggregated for OCI Criminality, TI CPI & FCN Country Score-1

Bottom of the Range % of Top of the Range % of GDP Corruption % of Proceeds If Corruption % of Proceeds If Corruption % of GDP If Score GDP Very High Levels (CPI) High Levels (CPI) Moderate Levels (CPI)

12 10.5% 12.5% 15-20% 10-15% 5%-10%

11 10% 12% 15-20% 10-15% 5%-10%

10 9.5% 11.5 15-20% 10-15% 5%-10%

9 9% 11% 15-20% 10-15% 5%-10% (Includes a V High)

9 8.5% 11.5% 15-20% 10-15% 5%-10% (No V Highs)

8 8% 11% 15-20% 10-15% 5%-10%

7 7.5% 10.5% 15-20% 10-15% 5%-10%

6 7% 10% 15-20% 10-15% 5%-10% (Includes a High)

6 6.5% 9.5% 15-20% 10-15% 5%-10% (No Highs)

5 6% 9% 15-20% 10-15% 5%-10%

4 5.5% 8.5% 15-20% 10-15% 5%-10%

3 5% 8% 15-20% 10-15% 5%-10% (Includes a Moderate)

3 4.5% 7.5% 15-20% 10-15% 5%-10% (no Moderates)

2 4% 7% 15-20% 10-15% 5%-10%

1 3.5% 6.5% 15-20% 10-15% 5%-10%

Note: TI CPI Scores below 50 are rated: 40-49 Moderate to High, 30 to 39, High, below 30 Very High; OCI Criminality Scores are rated: 6 or above at Very High, 5 - 5.9 at High, 4 - 4.9 Moderate and below 4 as Low; FCN Scores are rated: 1-19 - Extremely High, 20 - 29 Very High, 30 - 39 High, 40 - 49 Moderate - High, 50 - 59 Moderate, 60 - 69 Low- Mod, 70 - 79 Low, & 80 - 100. For Costs of Corruption, ranges then depend on the level of corruption based on TI’s Corruption Perception Index 2019 score. For more details on source information for the OC Index, see HERE52, for TI CPI Index see HERE53 and for the results for Nigeria for criminality for corruption and the FCN Country Risk Rating Score see Section 3 above.

Ghana - Threat Assessment - 2020 Page 30 of 34 2. Monies available for Laundering: Table A2 below illustrates how the final estimates for the range for “Monies available for Laundering” was established. The top of the estimated range is 76% of “Criminal Proceeds”, based on the findings of the UNODC 2011 Study, which found that of US$2.1 trillion estimated global proceeds, that US$1.6 trillion was available for laundering or 76%, and that most of this this was expected to be available to be laundered via the formal financial sector. Based on the relatively low levels of financial inclusion in most Sub-Saharan African countries compared with the rest of the world, and the size of the shadow and informal economies, as well as the ongoing dominance of cash within Sub-Saharan economies, the estimates available for laundering through the formal financial sector have been assessed with these factors in mind, based on the range estimates set out below, from sources estimating bank account and mobile money penetration. Ghana is rated “Moderate.” For more details on information on financial access, see HERE54.

Table A2. Ratings Range Matrix for Laundering by FCN - 2020

Financial Access Range % for Laundering Financial Access Range % for Laundering Criminal Proceeds Criminal Proceeds

V Low Access Levels 40-50 Moderate Access Levels 60-70 < 30% bank accounts AND >40% - 50% bank accounts <30% mobile money OR >40% - 50% mobile money OR vice versa

Lower Access Levels 50-60 Higher Access Levels 70-76 >30% - 40% bank accounts > 50% bank accounts OR OR >30% - 40% mobile money > 50% mobile money

3. Criminal Proceeds Involving Organised Crime: Table A3 below illustrates how the final estimates for the range for “Criminal Proceeds” involving organised crime was established. The top of the estimated range is 46% of “Criminal Proceeds”, based on the findings of the UNODC 2011 Study, which found that of US$2.1 trillion organised crime were involved in US$960 million or approx 46%. Table A3 takes the different scores for organised crime in Sub-Saharan African countries reported by the OC Index and presents an estimate, or range as a % of "Criminal Proceeds”, established as set out in Appendix 1 Section 1 above. Ghana is rated “Medium”. For more details on OC information, see HERE55.

Table A3. Ratings Range Matrix for Involvement by Organised Crime by FCN - 2020

Criminal Actors Score in OC Index Range % for OC Financial Criminal Actors Score in OC Index Range % for OC Involvement Involvement

Below 4 /10 in OC Index 2019 22-24 Rated 6 - 6.5/10 in OC Index 2019 32-34

Rated 4 - 4.5/10 in OC Index 2019 24-26 Rated 6.5 -7/10 in OC Index 2019 34-36

Rated 4.5-5/10 in OC Index 2019 26-28 Rated 7-7.5/10 in OC Index 2019 36-38

Rated 5-5.5/10 in OC Index 2019 28-30 Rated 7.5-8/10 in OC Index 2019 38-40

Rated 5.5-6/10 in OC Index 2019 30-32 Rated 8/10 in OC Index 2019 or above 40-46

Ghana - Threat Assessment - 2020 Page 31 of 34 Message from the Editor - FCN

This Country Threat Assessment focuses on the financial crime threats and responses and is both a stand-alone publication, but can also be read in conjunction with the Global Threat Assessment, published in 2019 and the Sub-Saharan Threat Assessment published in 2020. The Sub-Saharan Threat Assessment has been supplemented by this country threat assessment, as well as for other countries in Sub-Saharan Africa. The individual threat assessments have been co-created with dedicated financial crime fighters from the countries covered, and/or with the help of professionals familiar with the country and the region, based on a consistent approach researching available open source information. Judgement has been applied in deciding what to include and what to emphasise. Each threat assessment follows the same structure and includes the same main sources, usually over 60 sources from important and credible agencies, in the form of reports, papers and or ratings. The threat assessments include the results from the FCN Sub-Saharan Africa 2020 Risk Rating Scorecard which includes a significant number of these sources to aggregate the threats and the responses to derive a final rating and a final ranking

More Financial Crime Materials from FCN

Global Threat Phase 1 - 19 Country Sub Saharan Africa Sub Saharan Africa Assessment by FCN - Threat Assessments Country Risk Ratings Threat Assessment by 2019 by FCN - 2020 FCN - 2020

Available at: https://thefinancialcrimenews.com For Subscription for Commercial Businesses / Free to NGO’s and Policy Makers Or Contact the Editor: [email protected]

Author(s) & Editor The Co Authors of this work are John Cusack.. The Editor is John Cusack, the publisher is Financial Crime News / Metriqa Limited. All rights remain with FCN/ Metriqa Limited.

John Cusack is a leading financial crime fighter, Editor of the Financial Crime News, former Global MLRO at UBS and Standard Chartered Bank, Two time Co Chair of the Wolfsberg Group (to end 2019), and adviser to a number of financial institutions, Regtech Providers, and engaged with NGO’s combatting wildlife and human trafficking.

Acknowledgements: Thanks and appreciation to a number of colleagues and collaborators who freely gave their time, to research, comment and provide advice in connection with this Country Threat Assessment, including: Solomon Abiakalam, Ursula M’Crystal Hans Peter Bauer, Caroline Lamptey, Andrew Williams. & Hannah Cusack

Information to Note: The information, provided in this Country Threat Assessment is designed to help those involved in combating financial crime. The Editor (John Cusack) takes responsibility for the contents of this document, including any opinions, observations or recommendations, but does not take responsibility for referenced materials, that are the responsibility of the authors and as appropriate. References are provided for information purposes and do not constitute endorsement of any information. readers should be aware that website references listed may change.

Ghana - Threat Assessment - 2020 Page 32 of 34 Endnotes

1 See: https://www.state.gov/wp-content/uploads/2020/03/Tab-1-INCSR-Vol.-I-Final-for-Printing-2-25-20-508.pdf 2 See: https://www.state.gov/wp-content/uploads/2020/03/Tab-2-INCSR-Vol-2-508.pdf 3 See: https://www.transparency.org/cpi2019?/news/feature/cpi-2019 4 See: https://www.transparency.org/en/cpi/2018/results/uga 5 See: https://www.traceinternational.org/trace-matrix#matrix-results 6 See: https://www.transparency.org/en/gcb/africa/africa-2019/results/gha 7 See: http://reports.weforum.org/global-competitiveness-report-2019/competitiveness-rankings/?doing_wp_cron=1576075219.7585289478302001953125#series=EOSQ035 8 See: https://doc-10-a0-docs.googleusercontent.com/docs/securesc/5ngl9rhrnj2j6a0ko2ruv556imuug2bk/66i05ncvfvqi0iecn59c30jpna7gfmoh/ 1601745150000/12413811975934094395/09603970992484883907Z/1b4PF_VNSv5Ff-fCAcZc-Q9o71jogfK5E? e=download&nonce=433j8cf03cf0u&user=09603970992484883907Z&hash=5b3858qp1pjqldianq1h4rq0a0k0csic 9 See: https://www.wabicc.org/improving-wildlife-law-enforcement-when-the-trainee-becomes-a-trainer/ 10 See: https://doc-10-a0-docs.googleusercontent.com/docs/securesc/5ngl9rhrnj2j6a0ko2ruv556imuug2bk/66i05ncvfvqi0iecn59c30jpna7gfmoh/ 1601745150000/12413811975934094395/09603970992484883907Z/1b4PF_VNSv5Ff-fCAcZc-Q9o71jogfK5E? e=download&nonce=433j8cf03cf0u&user=09603970992484883907Z&hash=5b3858qp1pjqldianq1h4rq0a0k0csic 11 See: https://doc-10-a0-docs.googleusercontent.com/docs/securesc/5ngl9rhrnj2j6a0ko2ruv556imuug2bk/66i05ncvfvqi0iecn59c30jpna7gfmoh/ 1601745150000/12413811975934094395/09603970992484883907Z/1b4PF_VNSv5Ff-fCAcZc-Q9o71jogfK5E? e=download&nonce=433j8cf03cf0u&user=09603970992484883907Z&hash=5b3858qp1pjqldianq1h4rq0a0k0csic 12 See: https://doc-10-a0-docs.googleusercontent.com/docs/securesc/5ngl9rhrnj2j6a0ko2ruv556imuug2bk/66i05ncvfvqi0iecn59c30jpna7gfmoh/ 1601745150000/12413811975934094395/09603970992484883907Z/1b4PF_VNSv5Ff-fCAcZc-Q9o71jogfK5E? e=download&nonce=433j8cf03cf0u&user=09603970992484883907Z&hash=5b3858qp1pjqldianq1h4rq0a0k0csic 13 See: https://www.theguardian.com/environment/2019/jun/17/illegal-fishing-by-foreign-trawlers-costs-ghana-50-million-dollars-a-year-researchers-say 14 See: https://ejfoundation.org/reports/stolen-at-sea-how-illegal-saiko-fishing-is-fuelling-the-collapse-of-ghanas-fisheries 15 See: https://forestgovernance.chathamhouse.org 16 See: https://www.wri.org/blog/2019/04/world-lost-belgium-sized-area-primary-rainforests-last-year? utm_campaign=GFW&source=socialmediakit&utm_medium=gfwsocial&utm_term=2018tcl_4_2019 17 See: https://ourworldindata.org/illicit-drug-use 18 See: https://www.globalslaveryindex.org/2018/findings/regional-analysis/africa/ 19 See: https://www.globalslaveryindex.org/2018/findings/regional-analysis/africa/ 20 See: https://www.state.gov/wp-content/uploads/2019/06/2019-Trafficking-in-Persons-Report.pdf 21 See: https://www.state.gov/wp-content/uploads/2020/06/2020-TIP-Report-Complete-062420-FINAL.pdf 22 See: https://www.globalslaveryindex.org/2018/findings/importing-risk/cocoa/ 23 See: https://www.theglobaleconomy.com/Ghana/shadow_economy/ 24 See: https://www.bog.gov.gh/wp-content/uploads/2020/08/SUMMARY-OF-2019-FRAUD-REPORT.pdf 25 See: https://www.bbc.com/news/world-africa-32583161 26 See: https://www.itu.int/dms_pub/itu-d/opb/str/D-STR-GCI.01-2018-PDF-E.pdf 27 See: https://citinewsroom.com/2018/10/ghana-loses-230m-to-cyber-criminals-cid/ 28 See: https://www.theglobaleconomy.com/indi_menu.php?page_url=rankings&indicator=theft&type=0&withDataFor= 29 See: https://www.numbeo.com/crime/rankings_by_country.jsp?title=2020&displayColumn=0 30 See: https://www.statista.com/statistics/812039/youth-unemployment-rate-in-ghana/ 31 See: https://isis-online.org/uploads/isis-reports/documents/ThePeddlingPerilIndex2019_POD.pdf 32 See: https://sanctionssearch.ofac.treas.gov 33 See: https://www.fatf-gafi.org/media/fatf/documents/reports/mer-fsrb/GIABA-Ghana-MER-2018.pdf 34 See: http://visionofhumanity.org/app/uploads/2019/11/GTI-2019web.pdf 35 See: https://www.gov.uk/foreign-travel-advice/ghana/terrorism 36 See: https://documents.worldbank.org/en/publication/documents-reports/documentdetail/395721560318628665/fourth-ghana-economic-update-enhancing-financial-inclusion- africa-region 37 See: https://au.int/sites/default/files/documents/37326-doc-k-15353_au_illicit_financial_flows_devv10_electronic.pdf 38 See: https://secureservercdn.net/45.40.149.159/34n.8bd.myftpupload.com/wp-content/uploads/2020/03/GFI-Trade-IFF-Report-2020-Final.pdf?time=1583530239 39 See: https://secureservercdn.net/45.40.149.159/34n.8bd.myftpupload.com/wp-content/uploads/2020/03/GFI-Trade-IFF-Report-2020-Final.pdf?time=1583530239 40 See: https://au.int/sites/default/files/documents/37326-doc-k-15353_au_illicit_financial_flows_devv10_electronic.pdf 41 See: https://gfintegrity.org/gftrade/ 42 See: https://www.giaba.org/media/f/1067_ENG%20-%20Revised%20Post%20Plenary%20FUR%20Ghana%20-%20June%202018.pdf 43 See: https://www.fatf-gafi.org/media/fatf/documents/reports/mer-fsrb/GIABA-Ghana-MER-2018.pdf 44 See: https://freedomhouse.org/report/countries-world-freedom-2019 45 See: https://www.heritage.org/index/ranking 46 See: https://baselgovernance.org/sites/default/files/2019-08/Basel%20AML%20Index%202019.pdf 47 See: http://iiag.online 48 See: https://www.fatf-gafi.org/media/fatf/documents/reports/mer-fsrb/GIABA-Ghana-MER-2018.pdf 49 See: https://www.fatf-gafi.org/media/fatf/documents/reports/mer-fsrb/GIABA-Ghana-MER-2018.pdf 50 See: http://fic.gov.gh 51 See: https://rgd.gov.gh/Amended.pdf 52 See: https://ocindex.net 53 See: https://www.transparency.org/cpi2019?/news/feature/cpi-2019 54 See: https://datareportal.com/library 55 See: https://ocindex.net

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