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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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International character of Ghanaman and more

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Ghanaians can be found in every part of the world

The average modern Gold Coaster born and bred in Sikaman is an adventurous creature. Go to any part of the world and you’ll find Ghanaman diligently slugging it out either in the snow or in hot sweltering weather, earning a decent living.

Go to Guinea and see Ghanaman in the garb of a herbalist, curing the sick of various ailments. He makes the Guinean understand that not all diseases are caused by James Lucifer alias Jimmy Satan. On the contrary, most diseases are caused by kooko which can even attack the human nose and turn it upside down.

That kooko is also the cause of poverty and the internal bleeding of personal back-pocket economies. And that kooko can be cured using the chemistry underlying Sikaman herbal medicine which has been blessed by the gods of Larteh.

And before Ghanaman starts dispensing his herbal concoctions, he must attract the passing crowd with some Sıkaman-originated choreography, akin to a combination of adowa and agbadza, such that the dancer can easily dislocate a shoulder and start crying for his mother.

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When the crowd is enough to form a quorum, Ghanaman must perform magic as a side-attraction, and proceed to sell his drugs. The drugs are genuinely made from potent herbs which the Pharmacy Board of Sikaman says it has no confidence in. Believe me, Ghanaian herbalists are practising in neighbouring countries like Guinea, Cote d’Ivoire, Sierra Leone and Benin, while we are discouraging them from practising in Sikaman.

Go to Las Palmas and see Ghanaman as a fisherman. He sails on Korean-owned boats and is forced to eat garlic and raw tuna for radiant health. The garlic is also supposed to protect him against witches. But sometimes, he is not good bedfellows with some Korean crew members, and once in a while a fight breaks out.

The typical Korean is a Kung Fu expert and before displaying a golden dragon data. He must first terrify Ghanaman with a Korean dance which consists of wild arms and leg throwing. But Ghanaman is usually not daunted. Why has he been eating cancer kenkey all years without developing cancer? It mean is a superhuman capable of countering Kun fu side-kicks to the ribs.

Anyhow Ghanaman’s most potent arsenal lies in his fists. If he is a southpaw, it mean left fist is probably insured and can cause damage. When Ghanaman lands a cassava blow and it lands on a Korean chest, it has the effect of a cruise missile. If there is no ceasefire a funeral cannot be ruled out.

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Greenland

Go to Alaska and find Ghanaman there. Greenland, Iceland, Brazil, Argentina, Madagascar, everywhere and you’ll find him. He has become an international citizen and is generally lauded for his hardwork, sincerity and honesty.

However, some bad nuts are also condemned and despised.

The world and all its parts and corners are for the human race, and anyone can choose to live anywhere and earn a decent living so long as he doesn’t misconduct himself or become a social misfit and a law unto himself.

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Sıkaman for instance accepts foreigners, and we are so liberal that people just come in through our borders and we welcome them with the best palmwine in town and goat light soup. Who cares about passports and visas? Our hospitality is, as it were legendary.

So we have Liberians, Nigerians, Sierra Leoneans, Togolese, Europeans, Americans, Scandinavians and Koreans in Sikaman.  And some of them have misinterpreted our overzealous accommodation to mean “foolishness” and are misconducting themselves.

The newspapers carry stories of some unscrupulous Nigerians stealing, defrauding and collaborating with their Sikaman counterparts to rob people. You’ll find some good and law-abiding Liberians around but some other Liberians are in the business of fraud, robbery, money printing, money doubling, anything criminal.

Ghanaian hospitality can no longer be extended to such people. I do not think Ghanaians will be treated kindly either, when they misbehave anywhere in the world. Those who come from outside with the intention of bringing down their evil deeds and to practise them here professionally must be getting ready because Ghanaians are getting fed up with the menace.

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These days, you’ll find strange people following you as soon as you emerge from a bank. If you are not careful, they’ll wrestle your briefcase from you and speed away in a waiting taxi.

Someone was just saying that many foreign criminals are flocking to Ghana because in their countries, they are enable to operate either because they are being looked for by the police for offences committed or fear instant justice at the hands of mobs. Ghanaians, it is said, are humanitarian in dealing with criminals.

Well, in some African countries, a thief who is being chased runs directly to the police station in his own interest and begs the officer at the counter to lock him up. Otherwise he’ll be lynched or be burnt to death. In Ghana, it is the opposite. The thieves run far away from the cop stations.

The criminals must reform and stay peacefully in Sikaman or quit. No court case!

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This article was first published on Saturday September 5, 1998

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The architecture of existence: How we live and die

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​The human condition is defined by two absolute, biological bookends: the commencement of complex cellular animation and its ultimate, irreversible cessation.

For centuries, medicine treated life and death as strictly separate states. Today, modern pathology and molecular biology reveal a more profound truth: the mechanisms that allow us to live are the exact same mechanisms that dictate how we die.

​Understanding this relationship is no longer just a philosophical pursuit. It is a clinical necessity for managing public health in the 21st century.

Part I: How we live – The mechanics of animation

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​At its core, biological life is a continuous, high-stakes battle against entropy (the natural tendency of systems to degrade into disorder). To maintain form, consciousness, and function, the human body relies on three fundamental pillars:

1. Cellular respiration and energy production

​Every second of human life is powered by the conversion of oxygen and glucose into Adenosine Triphosphate (ATP), the universal energy currency of our cells. This process occurs within the mitochondria.

Without a constant supply of ATP, the microscopic pumps that maintain electrical gradients across our cell membranes fail, causing cellular collapse within minutes.

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2. Homeostasis: The balancing act

​To survive, the internal environment of the body must remain incredibly stable, regardless of external chaos. This balancing act, known as homeostasis, regulates:

​Blood pH: Strictly maintained between 7.35 and 7.45.

​Core Temperature: Ideally kept around 37°C (98.6°F).

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​Electrolyte Balance: Precise ratios of sodium, potassium, and calcium that allow nerves to fire and muscles to contract.

​3. The Autonomic Nervous System (ANS)

​The ANS acts as the invisible conductor of life, split into two complementary branches:

Part II: How we die – The path of cessation

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​Death is rarely a singular event; it is a progressive biological cascade. Whether caused by old age, chronic illness, or sudden trauma, the final pathways of mortality generally follow a predictable trajectory.

​1. The cellular horizon: Senescence and Apoptosis

​Every time a human cell divides, the protective caps at the ends of its chromosomes-telomeres-shorten. Eventually, telomeres become so depleted that the cell can no longer divide safely. It enters senescence (a state of permanent arrest) or triggers apoptosis (programmed cell death). This gradual, systemic loss of cellular renewal is the underlying engine of aging.

​2. The clinical cascade of somatic death

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​When the body can no longer maintain homeostasis, somatic death (the death of the organism as a whole) begins. This occurs in a distinct sequence:

1

Clinical Death

Zero to four minutes

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The heart stops pumping blood, and respiration ceases. While breathing and circulation have ended, the body’s tissues still contain residual oxygen and cellular energy reserves. At this stage, resuscitation is often still possible.

2

Brain Death (Infarction)

Four to six minutes

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Deprived of fresh oxygenated blood, the brain’s highly sensitive neurons begin to starve. Lacking ATP, the brain cells lose their electrical charge, swell, and begin to burst. Permanent, irreversible neurological damage occurs within minutes.

3

Biological Death

Hours to days

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The organs fail entirely. Without central control or blood flow, individual cells throughout the body consume their final energy reserves. Enzymes that once aided digestion begin to break down the body’s own tissues from the inside out, a process known as autolysis.

Part III: The modern collision of life and death

​In the modern era, the boundary between how we live and how we die has blurred. Historically, humanity died primarily from infectious diseases and acute trauma. Today, global mortality is dominated by non-communicable, chronic lifestyle diseases.

Modern Pathology: How we live (the cause) how we die (the result)

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Cardiovascular disease, chronic stress, poor diet, and lack of sleep keep the sympathetic nervous system hyper-activated, damaging blood vessels .Occlusion of coronary arteries leads to myocardial infarction (heart attack) or ischemic stroke.

Metabolic syndrome over nutrition and physical inactivity overwhelm cellular mitochondria, leading to systemic insulin resistance. Multi-organ failure, chronic kidney disease, and severe vascular complications.

Neurodegenerative Disorders Chronic systemic inflammation and sleep deprivation prevent the brain from clearing metabolic waste. Gradual loss of synaptic connections, leading to dementia and the eventual loss of basic autonomic functions.

Conclusion: The unified theory of health

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​Ultimately, how we live directly shapes the path of how we die. The micro-choices of daily existence-how we manage emotional stress, the quality of our rest, our communal connections, and our nutrition-either preserve the integrity of our homeostatic systems or accelerate their decline.

​True medical advancement is shifting away from merely extending the final, frail stages of biological death. Instead, the focus is turning toward optimising our living years-ensuring that the intricate, beautiful machinery of human animation runs smoothly until its natural, quiet conclusion.

By Robert Ekow Grimmond-Thompson

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