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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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Golden hour

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One more wedding. That’s what she’d told herself. Her portrait studio was already up and running, and she was done with the traveling and the fourteen-hour days and the family drama. Just one last wedding.

Jacqui checked the time on her phone for the umpteenth time and inhaled deeply. Screw it, the mindful breathing wasn’t cutting it. She caught the bartender’s eye. “Whiskey, please. Neat.”

She normally never drank at weddings–at least not until she clocked off. But this uncertainty was doing her head in.

She shouldn’t have agreed to the job, but it was Celia. Plus the new studio lights were expensive, and the groom was minted. Like, banking-money minted. This wedding was leaking money, from the exclusive manor-hotel venue with its manicured lawns, uniformed staff, open bar, to Celia’s dress, which Jacqui knew had been a gift from the groom’s corporate lawyer father. Celia had whispered that it cost “two months’s rent.” Who knew how much that might mean.

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Plus, she’d known Celia since grammar school in Cork. It would be like turning down family; she’d never have heard the end of it.

But then Celia had moved the wedding back two hours, and now Jacqui was screwed. She let the whiskey slide down her throat and its warmth seep up her spine.

How the hell to explain to a bride that you couldn’t take pictures during golden hour because of magic.

She should have cancelled.

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The last time Jacqui had shot a wedding at golden hour, the bride’s politician brother had appeared in every picture with a blurred mouth. He was arrested a week later on corruption charges, and every paper in the country had run headlines using the word ‘liar.’ Before that, it had been her own cousin’s university graduation, where he’d appeared transparent around the edges in every photo. A year later he’d abandoned medical school and cut ties with the family. Was now living in New Zealand, a diving instructor.

Jacqui never knew what truth might be revealed, or how cryptic or obvious it would be. She only knew she didn’t want the knowledge.

Curse the golden hour. And curse whichever social media wedding influencer Celia was following who had no doubt insisted the perfect wedding had to have flawless photos taken in the purest light, so her skin would look magazine-cover exquisite.

Oh, this was nuts. Why wasn’t she at home on her couch with Andy and Luna, drinking pinot and watching something benign on telly? Maybe Ted Lasso or even Breaking Bad. Something old. Something with an ending she already knew.

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The wedding planner was even now corralling the families towards the manor’s water feature. It would be fine if there was a chance in hell it would take less than twenty minutes to herd them all to one place, but wedding party guests were basically cats when it came to organisation. Even now they were milling around, new ones wandering off as lost ones returned.

Celia appeared on the grass, framed by the pristine white french doors of the bar area, which led onto the lawn. Gorgeous. And sweet. Did not deserve what was coming.

What might be coming? Jacqui liked the revised verb. Surely there had to be a chance that it wouldn’t happen again. Surely. Oh, quit kidding yourself. This had happened too many times to pretend and in too many different contexts. The magic worked on any camera, fancy or plain, expensive or crap.

Out there on the green, Celia was clearly at her wits’ end, searching for wayward relatives. It would be the twenty-somethings. Since they weren’t here at the bar, they were either at the hotel lounge, or in some corner having a sneaky spliff.

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The bride looked to her right, just at that moment, still framed beautifully, the golden hour just about to make its glorious appearance and transform the light into magic, figuratively. And literally.

Jacqui raised her water glass and Celia returned an exasperated smile just as Gavin joined her. As the couple spoke, heads bent towards each other, love clear on both faces, Jacqui raised her phone and snapped a shot. Heart pounding, she checked the image.

On the screen, Celia was kissing air. The groom had vanished.

There on the grass, solid and substantial; in the photo, absent.

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In the years since this golden hour trouble had started, she’d seen lies, grief, ghosts and once a man whose shadow walked three feet ahead of him. She’d never seen a bride or groom simply disappear.

“Bollocks.”

The bartender raised her eyebrows and tilted her head towards the whiskey, suggesting another drink.

“I wish. But no, thanks.”

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 Maybe she could fake a robbery of all her cameras. At least for an hour. She played the scenario out in her head: she’d exit the main bar carrying all her gear, and then come back moments later claiming a theft? Right.

She could feign illness. Some kind of sickness so debilitating that she couldn’t hold out for one hour…like a heart attack? Cue: a lifetime of guilt. Celia’s father had died of a heart attack. No, Jacqui couldn’t take the entire wedding down like that.

There was always the truth. After all, Celia’d grown up in Cork, where every family possessed at least one story nobody could quite explain. But no. This was her husband, and her wedding day.

Perhaps she should check again. Jacqui slid off her barstool and approached the french doors. From the threshold, she snapped a few more of the crowd. Several of Gavin, specifically, who looked perfect in this flood of golden light.

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She swiped through. There he was in the ceremony, saying his vows, holding the ring, kissing the bride, and walking up the aisle afterwards. All present and correct. But another swipe and there they all were, the whole wedding party, outside–all but Gavin. The groom was missing. Double bollocks.

Scanning the shots, in case some additional disaster had yet to reveal itself to her, it didn’t appear that any other guests were affected. Thank Hecate for that.

“I know it’s getting late. We’re almost ready, I swear.”

Jacqui jolted. It was Celia, who’d approached on stealthy-bride Manolos.

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“Oh–Hey. It’s fine. It’s nothing. Take your time.”

“Is everything alright? Your expression…are the photos okay?”

The eagerness in her bright blue eyes belied the question. Celia didn’t actually believe anything would be wrong with the pictures. This wasn’t even the right camera, just a phone. All the good, important shots would be on the expensive gear. “Totally fine! I was just checking–reading a text. All good.”

Celia nodded. “Honestly, I’m losing my patience. I’m giving them five more minutes and then they just won’t be in the family photos. You know?”

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Jacqui stretched her lips into a smile she didn’t feel. Wished for another whiskey to appear in her hand. Why didn’t the magic happen like that? Why with the damn photos?

“Jacqui, you look just like you did on the day Sean Ryan asked you to the Winter Dance. What aren’t you telling me?” Celia stepped closer, with laser focus on Jacqui’s screen. “Those are photos of today. Show me.”

She took the phone and peered at it. Frowned. Swiped. Swiped again, and again. Her frown deepened.

Jacqui winced. “I–”

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“Odd.” She swiped further back and paused. “He’s here.”

“Yeah.” “But not here.”

Jacqui shook her head.

“It’s funny…” But Celia didn’t finish the thought. She handed Jacqui the phone and waved at the bartender. “Two whiskeys, please.”

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“Bless you.”

“This is–” Celia bit her lip. “Come on.”

She marched to the bar, and Jacqui had no choice but to follow, grasping for something– anything–to say to explain the void.

“Do you know what it means?” Celia handed Jacqui a lowball tumbler.

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“No.” She shook her head with more certainty than she felt. “It’s the time of day. Something about this light reveals…something. I can’t even say ‘truth.’ Because I just don’t know.”

Celia sipped her drink, thoughtful, eyes on the lawn on the other side of the french doors, where the wedding planner was gesturing like a demented traffic warden. “They’ll be waiting. I have to go back out there.” She remained seated.

Jacqui tossed back her drink in one gulp. “We have to.” She savored the whiskey’s burn. This wasn’t the reaction she’d expected. Celia was still staring at the scene on the lawn, at Gavin. Maybe he wasn’t the doting fiance Jacqui assumed. Maybe Celia had already suspected that something wasn’t as it should be. An illness. Or an affair. Maybe she’d already spent months imagining a future without him.

“You should go. I’ll grab my gear.”

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Celia glided across the room in that Tuula Tatsuki sheath and those Manolo Blahnik stilettos, framed in gold by the light, which was even now changing. Darkening.

Perhaps the Golden Hour had passed. Maybe the danger was over.

Jacqui slipped her phone in her pocket and slung her bag over her shoulder. As she walked towards the lawn, she saw Celia take her place next to her husband, and Gavin look down at her with love. Celia didn’t look back. The light changed to blue.

The warmth of the whiskey evaporated as a chill ran straight up her spine. – Source:reedsy.com

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The saga of the dancing kiosk

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Some people being carried through flood waters

IN every society, there are people who please themselves and do things their own way, whether people will talk about them or not. Check out the man who, by some good fortune, came by some money to purchase a beautiful Benz bus. Instead of becoming a bossy transport owner to whom daily accounts will be rendered, he decides otherwise.

He hires a driver but no driver’s mate. He becomes the mate himself and the bold inscription on the back of the bus is ‘MAN NO FOOL’. Of course, he does not rank himself a fool. He has long observed the way drivers collaborate with mates to play Kwaku Ananse tricks with daily accounts. He is far and above such tricks.

What about the married man who decides to enforce the principles of division of labour? Early one morning, he decreed that he would start doing the daily market shopping all by himself because he suspected that his wife was “tearing chobo”

This domestic tyrant had, a month before this unilateral family decree, arrogated to himself the power of the kitchen ladle. According to him, he was not feeling the chop-money’s worth in his stomach and, therefore, decided to overthrow his wife and establish a new kitchen regime.

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He declared himself the chief cook and the wife a steward. He told his enquiring friends that he was forced to take the stringent measure because whenever his wife fetched the soup, his share looked like that of a prisoner although he is the one who “moves the chopmoney”.

He calls his actions “domestic pragmatism” and when the wife completes the cooking, she arranges the plates and bowls and calls out to the chop-money man to come and fetch the soup and allocate the meat.

Also, consider the noble ways of a man and wife who have a kiosk in which they sell their wares. Because they cannot carry their goods home back and forth everyday, and taking care not to be burgled, they decide to sleep in the kiosk every night although they have a house.

Last week Tuesday, they were fast asleep when the rains started. Deep in slumber, each one of them began dreaming he (or she) was dancing in a jamboree. It was indeed a real boogey, but two people side by side and dreaming simultaneously about dancing was too mysterious on a rainy day to be true.

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When they came around and opened their eyes they realised that is was not a disco night, after all. The kiosk in which they were sleeping was rather water-borne and was doing the Michael Jackson dance, tossing up and down enroute to the abode of death. The magnificent dream dance turned out to be a Music-For-Your Dancing Kiosk.

Unfortunately, the dream dancers did not die in the floods. They lived to tell their story. They were one of the fortunate ones who escaped death by the skin of their teeth. Others were not so fortunate with water.

Death and Mourning!

It turned out that on that Tuesday, 24 residents of Accra were sentenced to death by water squad. It was a pitiful experience for many when the rains, the heaviest in 59 years, destroyed property, drowned human beings and animals and precipitated the worst traffic jam that ever hit the capital.

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I was at home when Radio GAR (no longer GBC FM) announced that the situation was quite precarious and that the flood action was happening live Circle, the Odaw River overflowing, blah, blah, blah! Well, when you live in a planned city like Tema, you see rain but not floods and boogeying kiosks.

Neck Insurance

I had gotten dressed up for work but the announcement made me take off everything and got firmly tucked in bed as the rain drizzled even at about 9:30 a.m. having fallen from 11:00 p.m. the previous day with such intensity that I was surprised Tema was not inundated.

When I got to Circle the next day and saw the extent of damage, I was overawed. I heard people had to transform into human transport, carrying people in waist-deep water across for a fee of ₵500. Luckily I wasn’t around to be carried. I would have been charged ₵1,500 because the carrier would have had to first, insure his poor neck against dislocation since my weight is quite helluva! In any event of injury he would have tossed me into the water, anyway, to save his neck. You joke with your neck and you’ll die young!

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When I got to the office on Wednesday, it was a mess. Workers and labourers were carting out soaked material and drying the offices. I had left my office radio on the carpet floor and I guess it did a bit of swimming before it was rescued. When it got dried a bit, I tried it and it cackled to life.

Jesus Christ, the radio must be holy-ghost filled. Perhaps, it walked on the water. I was so glad and tuned in to BBC, hoping something would be said about the floods in Sikaman. Nothing! Only Bosnian Serbs and their atrocities and that kind of boring stuff. People killing themselves and never stopping,

And it came to pass that Mr Nat Nunoo-Amarteifio, the AMA boss, came on the air later on to undertake a post-mortem of the disaster. Among other things, he talked about the level of the sea and lagoon rising to meet the floods. As for that explanation I was not convinced at all, but I won’t comment

You see, one veteran journalist whom I respect so much because of his prophetic genius, is TOM DORKENOO. He is, a man from whom I often take counsel because of his experience in life and journal-ism. Whatever he predicts comes to pass and recently I suggested that he should establish a church so that he could prophesy both day and night.

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Uncle Tom as he is fondly known, wrote an article in his column two years ago, enumerating in graphic detail, reasons why Accra is a disaster area as far as floods are concerned, concluding that if the authorities do not take radical steps in tackling the drainage issue and allied problems, we must expect deaths and disaster in all forms and ramifications.

A year later, people died in the floods. The dose was repeated this year with 24 people losing their lives. Many have lost their animals and property and have been thrown into debts they can never redeem.

It is not enough for Nunoo-Amarteifio to come on the air to talk about actions he wants to take concerning the drainage system and unauthorised buildings. He should get down to work and see to it that everything that is contributing to the yearly floods is tackled appropriately.

If he is in doubt, he should look for back copies of the ‘Weekly Spectator’ and scan for Uncle Tom’s article. Tom is a man of the environment. He has talked extensively on floods and earthquakes.

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Yes EARTHQUAKES! How prepared are we?

This article was first published on Saturday, July 15, 1995

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