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The National Assayer – PMMC’s role in providing revenue assurance to government on gold exports

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Nana Awuah,MD (PMMC)

On 26th January, 2022, www.myjoyonline.com published a story captioned “Ghana loses over $2bn in taxes to undervaluation of gold exports”. According to the story, these losses were identified through a research by a consortium including the Institute for Statistical, Social and Economic Research (ISSER). It is observed that the research, which covered 2011 to 2017, does not disclose which sector it focused on – large scale or small scale. This distinction is important because the two have separate tax regimes.

Undervaluation of Gold

Upon reading the news story, the press release by the research team and the presentation of the research findings, it is difficult to ascertain the basis for the claim of undervaluation.

Undervaluation of a commodity such as gold presupposes that there is a true standard value against which the commodity can be measured. The standard value of gold is easily verifiable. Within the international market, bodies such as the London Metal Exchange (LME) are reputed indicators of the global market price for gold. It is important to mention that the prices as set by the LME on a daily basis are for refined gold of 99.99 per cent 24 karats purity. Gold exported from Ghana are unrefined and hence would not attract the same price as set by the LME.

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Within the precious minerals industry, it is trite knowledge that gold values are dependent on weight and purity. Hence, a kilo of unrefined gold would not have the same price as a kilo of refined gold. Similarly, two kilos of 14karats gold could be less expensive than a kilo of 22 karats gold. Given that gold exported from Ghana are in unrefined doré form with a purity range of about 21 carats to 22.5 karats, without an independent valuation exercise, it will be misleading to say that such gold doré has been undervalued using the prevailing world market price as benchmark.

Valuation of Gold

As earlier indicated, two variables go into the determination of the value of gold – weight and purity. Measuring the weight, which is done with a scale, is quite easy and straightforward. Determining the purity of gold is through a scientific process known as assay.

There are various methods of assay – non-destructive methods such as X-ray Fluorescence (XRF), Specific Gravity or Density, and Ultrasonic Testing; and the destructive method which includes the Cupellation (Fire Assay).

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Once the weight and purity are identified, a calculation is done using the world market price to ascertain the true estimated value of the gold doré.

From the foregoing, therefore, it is deductible that to substantiate a claim of undervaluation, it is important to know the weight and purity of what was exported as well as the then prevailing world market price of gold. Undervaluation may arise where there is a false declaration of the weight and purity of the gold doré which is being exported. The report, however, does not indicate whether there were any such findings of false declarations of weight and purity.

As earlier mentioned the research fails to disclose which sector of the gold mining industry it focused on – small scale or large scale. This is important because the two have distinct tax regimes. Whereas the large scale sector has a tax regime which includes royalties and corporate tax, the small scale sector presently attracts a withholding tax of 1.5 per cent on gold exports.

PMMC’s Mandate as National Assayer

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In 2017, President Akufo-Addo directed that government identifies a way to independently verify gold exports in order to ensure that the country is obtaining maximum revenue for this precious mineral resource. Consequently, under the leadership of Hon. Kiston Akomeng Kissi, PMMC Board Chairman and driven by Hon. Kwadjo Opare-Hammond (may his soul rest in peace), then Managing Director of PMMC, stakeholder engagements began towards the implementation of this directive. There were several engagements with the Ghana Chamber of Mines and the Association of Gold Exporters, now Chamber of Bullion Traders, Ghana to agree on modalities for the smooth take-off of the National Assay Programme. Eventually, with the support of the Vice President and the then Sector Minister, in February 2018, PMMC officially commenced operations as the National Assayer with the mandate to assay all gold earmarked for export from Ghana.

The National Assay Laboratory located at the Kotoka International Airport, from where PMMC carries on its operations was set up through the support of the Minerals Commission with funding from the World Bank. The Assay Lab is fitted with three non-destructive assay equipment – an XRF Machine, a Specific Gravity equipment and Ultrasonic Testing device.

PMMC’s mandate as National Assayer covers both the small scale and large scale mining sectors. As National Assayer, PMMC independently verifies the weight and purity of the gold doré being exported in order to ascertain its value. The value as determined by PMMC enables the Ghana Revenue Authority (GRA) to exact the requisite taxes such as the 1.5 per cent withholding tax on the gold doré before export.

For the small scale sector, after the assay analysis by PMMC, the export is managed through the ICUMS systems with close supervision by the Central Bank. Exports are done by duly licensed export companies who are required to repatriate 80 per cent of the proceeds back to Ghana within thirty (30) days. Failure to show proof of repatriation of export proceeds comes with sanctions such as prevention from doing further exports and upon persistent breach, revocation of export licence and possible prosecution.

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For the large scale sector, whose tax regime is entirely different from that of the small scale, PMMC has field officers who observe the smelting of gold in their gold rooms. From the gold room, the weight of the bars are recorded and samples taken. The samples are transported via helicopter to the National Assay Lab where PMMC conducts the assay analysis to determine the purity and by extension the values of the gold doré which are to be exported. This provides an independent verification of the export values thereby providing revenue assurance to government. Periodic reconciliations are carried out between PMMC and the large scale mining companies represented by the Ghana Chamber of Mines.

It is worth mentioning that since the commencement of the Domestic Gold Purchase Programme by the Bank of Ghana in June 2021, PMMC as National Assayer has been providing this essential service to the Central Bank by independently verifying the weight, purity and by extension value of gold supplied for purchase.

Digitalisation of National Assay Laboratory

Since the commencement of the National Assay Programme in 2018, there have been consistent efforts to make improvements so as to ensure maximum efficiency of the programme. In 2021, again under the leadership of Hon. Kissi, with support from the Sector Minister, Hon. Samuel A. Jinapor and driven by the present author, the National Assay Programme was digitalised. Digitalisation now made it possible to generate assay certificates which bore unique security features making it difficult to forge to facilitate the dubious elaborate schemes of gold scammers.

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Digitalisation has also now made it possible to monitor in real time, gold exports passing through the National Assay Laboratory. It has improved collation of timely data on export figures and revenues in order to aid effective national economic planning.

The digitalised National Assay Lab, which will be officially launched this month, will be open and accessible to key stakeholders including the President as the Constitutional Trustee of Ghana’s mineral resources, the Vice President as Head of Economic Management Team, the Minister of Lands and Natural Resources, the Minister of Finance, the Governor of the Bank of Ghana, and the Commissioner General of the Ghana Revenue Authority. 

PMMC continues to find ways to improve upon the execution of this important mandate which is critical for securing the much-needed revenue from the precious minerals industry for national development.

By Nana Akwasi Awuah, Managing Director, Precious Minerals Marketing Company (PMMC)

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Just as He said

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This week I have a very strong desire to put on my Apostolic Cap and talk about the power available to children of God which we can utilise to generate positive outcomes, in our lives. 

There is a phrase in the Bible that if Christians meditate on, can immensely transform their lives.  In Matthew 28:6 there is a phrase “… as he said…” according to the King James Version. 

Thus phrase forms part of a statement declared by an angel of God to two women who were disciples of Jesus who had gone to his tomb early in the morning on the third day after his death. 

According to the Biblical account, the stone covering the entrance of the tomb had been rolled away and an Angel was sitting on it and he made the statement to the effect that the Jesus they are seeking is not there and that he had risen, as he said before his death.  

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His resurrection affirmed the authenticity and dependability of the word of Jesus and therefore the word of God.

Christianity has to do with faith in the word of God.  Pastor Mensa Otabil said if we view Christianity as an inside out view, you would go inside to operate the power that is in you.  

As a Christian, the spirit of God and therefore the power of God, dwells in you.  Anyone who is aware of this truth, does not go around seeking to have a so called powerful person resolve his or her spiritual issues.  

Most Christians who move from prophet to prophet, do not believe that the spirit of God which operates in a Pastor or Prophet, is the same spirit that dwells in him or her.

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 In fact , that Christian may be more ‘powerful’ than the Prophet or Pastor he is going to for prayers because he is living a holy life, which is pleasing to God, for God is no respecter of persons according to Acts 10:34-35.

 God does not give out his spirit in different measures to indwell believers.  The spirit of God that dwells in a new convert, is the same spirit that dwells in a Bishop or a Prophet or an Evangelist or an Elder or a Deacon.

All you need to do as a child of God is to believe in the word of God and know that it works and that according to 1 John 4:4 we, Christians, that the Spirit of God dwells in us have overcome the world and Jesus in us, is greater than the Devil who is out in the world, wrecking havoc all around.

If we realise that we have overcome the Devil and everything he controls, then we can believe and act in faith and make declarations and just as Christ declared that he will die and on the third day, he will rise from the dead and it manifested as he said, there shall be a manifestation of our declarations also.

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The problem of modern day Christians is that, a lot of them, do not study and meditate on the word of God, so they do not witness the manifestation of the power of God, in their lives. 

Such an experience over time, give them the impression that the spirit of God dwells in different dimensions in believers.  This then leads them to seek solutions to their challenges from so called powerful men of God. 

Some Pastors also fall into this misconception of the measure of the spirit of God in believers.  When the size of a Pastor’s church for instance, is not increasing the way he had been praying for self-doubt sometimes begin to set in. 

Especially, if he begins to compare his church with that of say a colleague from the same Bible School, then he begins to wonder if there is not a spiritual secret he is not aware of. 

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This is when, if care is not taken, fellow Pastors who appears to be very successful in the ministry but are using occultic powers, could sway them from the narrow path and get them trapped in the Devil’s clutches and eventually and inevitably, destroy their lives. God bless.

By Laud Kissi-Mensah

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Decision paralysis: Why more choice kills action and how to break the loop- Part 1

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Introduction

You have been there. Twenty tabs open comparing laptops. A blank page for an email you’ve been “thinking about” for three days. A menu with 30 options and you leave hungry.

This is decision paralysis: the state where the volume of information, options, or perceived stakes prevents you from making a decision at all. It’s not laziness. It’s a cognitive overload response.

 In a data-rich environment, it’s becoming the default mode for both individuals and organisations.

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This article breaks down why it happens, how it shows up, what it costs, and how to break it.

 1. What decision paralysis actually is?

Decision paralysis is a failure of the decision-making system to convert information into action. Psychologists call it ‘analysis paralysis’ or ‘choice overload.’

It has three components:

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1. Cognitive overload: Working memory can hold between four to seven chunks of information at once. When you try to track 20 variables, the system freezes. 

2. Anticipatory regret: You overestimate the pain of making the wrong choice. The brain avoids the emotional cost by avoiding the choice. 

3. Ambiguity aversion: Humans prefer known risks over unknown ones. When outcomes are uncertain, we stall.

The result is not neutral. Not deciding is a decision. It costs time, momentum, and opportunity

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 2. Why it’s getting worse now

2.1 Infinite options

Amazon has 350 million products. Netflix has 6000+ titles. Dating apps have unlimited profiles. The paradox of choice: more options increase initial satisfaction but decrease final satisfaction and increase regret.

2.2 Information abundance without synthesis

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You can find 50 studies on sleep. Each one has caveats, conflicting results, and different methodologies. Without a framework to integrate them, more data creates more confusion, not clarity. This connects directly to the “data-rich, wisdom-poor” problem.

2.3 Reversibility anxiety

In the digital age, most decisions feel permanent. A bad post goes viral. A bad hire is public on LinkedIn. A bad career move is visible. The fear of irreversible error makes people delay.

2.4 Algorithmic mirroring

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Platforms show you what you already engage with. This creates an illusion that there’s one ‘best’ option you are missing. You keep searching, convinced the optimal choice is one more scroll away.

 3. How it shows up

Personal Level

Cannot pick a career path after six months of ‘research’

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Spend two hours choosing a movie and watch nothing

Delay sending an email because it ‘isn’t perfect’

3.1 Organisational level

Teams spend 80 per cent of time in meetings gathering data, 20 per cent deciding

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Product teams delay launch waiting for “one more data point”

KPIs multiply but no strategic choice is made

3.2 Common cognitive tells:

Endless comparison tables

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Asking for one more opinion

Reframing the problem instead of solving it

Feeling drained after thinking but not acting

By Robert Ekow Grimmond-Thompson

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