Features
The National Assayer – PMMC’s role in providing revenue assurance to government on gold exports
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.
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).
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
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.
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.
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)
The driver stopped the vehicle at the gate of the large, fenced property along the Nsawam Highway, and Kakraba stepped out to meet the several workers who had gathered to wait for him.
He greeted them and went straight to the point.
“Gentlemen, I am glad to see that you have almost completed the clearing of the land. I’m happy to report that we have concluded all arrangements with Nana Serebour, and construction of the palace will start in a few days.
“I will need you to go and level the ground, and then come back to start this project. Some workers from a construction company will come and join us.
“My plan is to build twenty houses in four months. Then we will do twenty more until we reach two hundred.
“I am relying on you to help me deliver good-quality work to satisfy our clients and, as I have already indicated to you, I will reward you for your work.”
After an hour’s discussion, he closed the meeting and moved to drive away. Wofa Yaw drew closer.
“Director, can you please spare me five minutes? I would like to discuss a small issue.”
“Why, Wofa Yaw? Your wife has threatened to leave you?”
“No, Director. My wife will never leave me. This concerns a young niece of mine.”
“I hope it’s something I can help with. Please sit in the car and let me hear you.”
“Boss, my niece, Beesiwa, is a polytechnic graduate, very beautiful and with very good character.
“Unfortunately, her parents virtually forced her into a relationship with an idiot based in the US, which affected her badly. She has now recovered from that experience and, Boss, I am respectfully asking if you would find a job for her.
“I promise you that you will never regret it.”
“Well, Wofa Yaw, let me meet her and speak with her. I may be able to help, maybe not in the way you expect, but let me meet her.
“I will not be back here for another week, but I will be at the office throughout next week. You can come with her.”
On Monday morning, Wofa Yaw and Beesiwa were seated at the office by nine o’clock. Three young ladies welcomed them warmly, offered them soft drinks and assured them that Kakraba would be there shortly.
They then returned to their desks and sat behind computers with large screens displaying various building designs.
Kakraba walked in and greeted them warmly. After chatting briefly with the three ladies, he ushered Wofa Yaw and Beesiwa into his office.
“Director, this is my niece, Beesiwa. I mentioned her to you when you came to Nsawam.”
“Yes, indeed. Madam Beesiwa, you are very beautiful, just as your uncle said. Wofa Yaw is my colleague.
“We have just started a building project that will take about three to four years. He mentioned that you have a small problem, so I said I would like to meet you and see how I can help.
“So, Beesiwa, please tell me a little about yourself.”
Beesiwa described her childhood, her school experience, her brief work at the bank and the nasty episode with Sammy Abrokwa, which shattered her peaceful life. She also explained how she had been recovering from the experience.
“I am really sorry to hear this,” Kakraba said. “Now, here is what we are going to do.
“We are a small but very busy company. The three ladies out there spend most of the day on site and come back to report on their work in the morning.
“I have three main projects. The big one is an estate project in Nsawam, where your uncle is one of my main colleagues. I need a personal assistant who can take care of my activities, especially when I am not in town.
“Now, we will have to start with trust. Based on what I know about Wofa Yaw, and based on what you yourself have told me, I think we can start on a sound basis.
“So, Wofa Yaw will take you to my home. You can move into one of the four guest rooms.”
“Sir, I have taken some computer lessons, and I have even done graphics and web design,” Beesiwa said.
“Fantastic! I will give you a good phone and a laptop. I will also arrange computer lessons for you.”
“Now, Wofa Yaw, take her home. My sister, Kuukuwa, will meet you and show you around, and then you can return to Koforidua.
“When would you like to start work?”
“Sir, I would like to start today, but I would need to go and bring my things.”
“No problem. Take a taxi to my house, meet my sister, and let me know what you decide.”
Later that day, Kakraba and the three ladies met with some bank officials to conclude the sale of the three buildings at Adabraka.
They closed at five-thirty and, after rewarding the ladies for their hard work, Kakraba got home just after dark.
He was surprised to find Kuukuwa and Beesiwa sitting at the table enjoying supper.
“What’s happening here?” he asked. “Beesiwa, I thought you would return to Koforidua.”
“She changed her mind,” Kuukuwa said. “We went to the mall and bought a few things for her. Then we came back to cook. She has made some nice changes to your bedroom and cooked a couple of interesting dishes. Sit down; we will serve you.”
“Well, I certainly can’t refuse that. It’s been a busy day.
“So, what’s the plan now? Will Beesiwa go to Koforidua tomorrow, gather her things together and come down?”
“No, I will stay here for a while,” Beesiwa replied. “Kuukuwa bought me the things I need, so I may go back next week. I’m ready to start work. What would you like me to start with?”
“Well, you can come to the office tomorrow morning, meet the three girls and get a feel for what we do.
“Since you are living here, at least for now, we can discuss the plans for the next few weeks.
“Sometimes there are gaps when I travel up north. You can take care of things from now. I think the girls would like having someone like you around.”
By Ekow de Heer
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A frequent question following breast surgery is whether human tissue possesses the regenerative capacity to restore an excised organ.
From a strict physiological standpoint, a completely removed breast cannot regrow. Unlike certain organisms that can regenerate complex limbs or organs, adult human tissues—particularly specialised glandular structures—lack the cellular machinery required to rebuild an entire organ after its total surgical removal.
Instead, the body heals the surgical site through processes such as scar tissue formation and re-epithelialisation rather than complete cellular regeneration.
What a mastectomy actually removes
To understand why natural tissue regeneration does not occur, it is important to examine the surgical scope of a mastectomy.
Depending on the type of procedure and the medical reason for surgery, a mastectomy may involve the removal of:
Glandular architecture: The milk-producing lobules and ducts that form the functional core of the mammary gland.
Adipose tissue: The fatty tissue that contributes to breast volume, projection and contour.
Other breast tissue: The extent of tissue removal varies according to the type of mastectomy and the need to achieve appropriate surgical clearance.
Because specialised breast structures are physically removed, the body does not rebuild a complete mammary gland. Instead, healing occurs through tissue repair and scar formation.
Distinguishing residual tissue from “regrowth”
Patients or observers may notice changes in the chest area after surgery, sometimes leading to misconceptions about tissue regeneration.
Skin- and nipple-sparing procedures
Modern breast surgery may preserve the outer skin envelope or, in selected cases, the nipple-areola complex. Small amounts of breast tissue may remain depending on the surgical technique. Any changes in remaining tissue due to hormonal fluctuations represent residual tissue responding to the body, rather than the regrowth of a completely removed breast.
Adipose accumulation
Weight gain after surgery can increase the amount of subcutaneous fat across the chest wall. However, this is part of general body fat distribution and does not represent the regeneration of a mammary gland.
Modern reconstructive pathways
Because a completely removed breast does not naturally regenerate, modern medicine offers reconstructive options aimed at restoring physical symmetry, contour and body image.
The two main approaches are implant-based reconstruction and autologous, or tissue-based, reconstruction.
Implant-based reconstruction
Implant-based reconstruction uses synthetic medical devices, typically filled with silicone gel or saline, to rebuild the breast mound following a mastectomy.
The two-stage process: This approach may begin with the placement of a temporary tissue expander to gradually create space and stretch the surrounding tissues. A later procedure may then be performed to place a permanent implant.
Recovery profile: Implant-based reconstruction generally involves a shorter initial surgery and recovery period compared with procedures that require tissue to be harvested from another part of the body.
Long-term considerations: Breast implants are not lifetime devices and require ongoing medical monitoring. Some patients may need additional procedures over time because of complications or changes in the implant or surrounding tissue.
Autologous or tissue-based reconstruction
Autologous reconstruction uses the patient’s own living tissue to create a new breast mound. Tissue may be transferred from another part of the body, commonly the lower abdomen, using procedures such as a DIEP flap.
Natural look and feel: Because the reconstruction uses living tissue, it can provide a natural warmth, texture and softness. The tissue may also change with the patient’s body weight over time.
Long-term durability: Once healing is complete, autologous reconstruction can provide a long-lasting result without the need to replace an implant. However, some patients may still require further procedures.
Complex surgery: This option usually involves a longer operation and recovery period. In microsurgical procedures, surgeons may need to reconnect tiny blood vessels to establish blood flow to the transferred tissue.
Direct comparison
When choosing between these two reconstructive pathways, patients and their surgical teams must consider several physical, medical and lifestyle factors.
Surgical burden: Implant surgery is generally less invasive, while flap reconstruction involves surgery at both the chest and the donor site.
Foreign material versus native tissue: Implants involve the use of a medical device, while autologous reconstruction uses the patient’s own tissue.
Recovery: The recovery timelines and rehabilitation requirements differ significantly between the two procedures.
Recovery and physical rehabilitation
Recovering from breast reconstruction requires patience, careful pacing and, in some cases, structured physical rehabilitation.
Because implant-based and autologous tissue-flap procedures involve different surgical techniques, their healing timelines and physical therapy milestones can vary considerably.
Understanding these differences is important for patients considering reconstruction, as the choice involves more than restoring physical appearance. It also requires careful consideration of recovery, long-term monitoring, lifestyle and individual medical needs.
Part 2 will examine recovery timelines, physical therapy milestones and other factors patients should consider when choosing between reconstructive options.
By Robert Ekow Grimmond-Thompson
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