Financial and banking consultant Dr. Richmond Atuahene has proposed a comprehensive action plan to tackle trade based money laundering (TBML), which he describes as one of Ghana’s biggest financial threats draining billions and weakening the cedi.
The proposals, drawn from years of experience and recent revelations of phantom shipments worth over 42 billion US dollars, call for accountability, technology upgrades, training, and structural reforms across Ghana’s financial and trade ecosystem. The plan addresses weaknesses in banking, customs, enforcement, and institutional discipline.
Dr. Atuahene wants the government to establish a Commission of Enquiry to investigate the 42 billion dollar phantom shipment scandal and other suspicious trade flows flagged in recent media reports. The Commission would conduct a forensic audit, identify culprits, and recommend tough sanctions, taking inspiration from the United Kingdom’s 5.8 million pound fine against Ghana International Bank in 2022 for weak anti money laundering controls.
On banking reforms, he insists that financial institutions must overhaul how they vet clients by strengthening Know Your Customer (KYC), Know Your Customer’s Business (KYCB), Customer Due Diligence (CDD), and Enhanced Due Diligence (EDD) processes for high risk cases. The Ghana Card must become the anchor identification document for all verification processes, he argues.
Banks should also put in place tighter internal systems to check customer activity, screen names against sanctions lists, and report suspicious behaviour to the Financial Intelligence Centre (FIC) without delay. Regular independent audits must be mandatory, according to the consultant.
All 23 authorized dealer banks should deploy automated monitoring systems that use data analytics to flag suspicious trade patterns instead of relying on manual reviews. Dr. Atuahene calls for strong integration of artificial intelligence (AI) and machine learning to spot anomalies in trade documents, detect misinvoicing, score risk levels automatically, and track unusual patterns instantly. This would replace outdated rule based systems that criminals easily outsmart.
He proposes blending blockchain and AI cloud systems to create tamper proof digital records of trade transactions, making it far more difficult to falsify invoices and forge shipment information. Suspicious Transaction Reports (STRs) and Cash Transaction Reports (CTRs) must be filed automatically using analytics and blockchain based transaction tracking.
Banks should allocate resources to where the danger is highest, especially in international trade finance, rather than treating all transactions equally. This risk based approach would focus attention on the most vulnerable areas, Dr. Atuahene explains.
On human capacity, bank workers and staff of financial institutions must undergo regular training on trade practices, TBML red flags, emerging criminal techniques, and Anti Money Laundering and Combating the Financing of Terrorism (AML/CFT) regulations. This is essential because criminals are now more technologically savvy.
Customs officers at borders, ports, and airports need firm enforcement powers, more patrols and inspections, modern surveillance tools, and stronger border protection. They are the country’s first line of defense against misinvoicing and trade fraud, the consultant notes.
The Ghana Revenue Authority (GRA) must roll out AI based systems, cargo manifest analysis tools, electronic invoicing, and digital auction platforms to reduce human interference and curb corruption. The plan calls for more scanning technology, extended inspection hours, data driven intelligence gathering, and proactive investigations targeting suspicious networks.
Dr. Atuahene says GRA must step up arrests and prosecutions under Act 891, working closely with Bank of Ghana (BoG), Economic and Organised Crime Office (EOCO), FIC, Criminal Investigation Department (CID), and the Military. Strong enforcement would set a deterrent tone.
Ghana must break the silo system, he insists. Banks, GRA, FIC, EOCO, and BoG must share intelligence seamlessly to close loopholes that TBML thrives on. The two key institutions, banks and GRA, must share data to identify irregularities between trade flows and cash movements, a core weakness exposed in the phantom shipment scandal.
The plan also calls for ethics training for customs officers, protection for whistleblowers, sanctions for corrupt officers, an independent oversight unit, and stronger public transparency. Public trust, he argues, is essential to cleaning up the system.
Finally, Dr. Atuahene recommends reappointing a Destination Inspection Company to inspect goods upon arrival to verify quality, confirm correct values, ensure proper customs classification, and prevent smuggling and underinvoicing. This would further close the loopholes that criminals exploit.
Ongoing training for customs staff needs to focus on new TBML tricks, technology tools, trade procedures, and high risk commodities to keep officers ahead of criminals.
If implemented, analysts say Ghana could save billions in lost taxes, protect the cedi, restore integrity to trade systems, and safeguard national revenue. The comprehensive approach targets systemic vulnerabilities that have allowed trade based money laundering to flourish in recent years.
Source: newsghana.com.gh



