Minerals Board, My Take to deal with the Menace and the loss of revenue with Small Scale Mining

Activities of Artisanal and Small Scale Miners are reported globally as a danger to the local environment, Agriculture, to themselves and to people close to Artisanal and Small Scale Mining. It is generally an irresponsible informal mining method done mostly by rural people (over 4 million in Ghana) including children and women (over 30 percent in Africa as per report of the World Bank, ILO and USAID).

Small Scale Miners think that the minerals (Gold or Diamond Sapphire or Salt) is a gift from God for them to escape from their poverty miseries. So, they work with their hands or with simple tools, with no or little capital or money for survival and not necessary for wealth creation. Though it is a danger to the environment, Agriculture, themselves and people near the activities of Small Scale Miners, it has the potential to create numerous jobs and source revenue for both affected rural communities and the Nation.

Some Small Scale Miners are with the misconception that a loss of blood is an indicative of good omen for their mining activities hence need to inculcate a good mindset thinking including the repercussions of Small Scale Mining.

The above characteristics of Small Scale Mining are indicative of the need for interventions by Governments of affected Countries with the support of the Community and Opinion Leaders, World Bank. ILO, USAID, FAO, Environmental Organization, associated Large Scale Mining Companies to reduce the associated risks to the barest minimum by regulating it through effective legalization and formalization process to bring it to the formal or official sector.

The interventions can be done through all ranges of measures among others by Politically and Economically, Socially, Inspectionally/Militarily and, Psychologically/ Religiously

Politically and Economically; This will require the need for the understanding small scale mining as a means for survival, so as to come out with good laws to develop entrepreneurship, make it an environmentally friendly and sustainable project. This should by Cooperative or Community Small Scale Mining Projects for interested affected communities. Help them with credible leaderships (local governance), so that one can deal with the leaders to control them, provision of Alternative Livelihood Projects including the application of sustainability in mining by helping them to navigate into other profitable business, hence investment awareness programs for operators. The state should come out with Medium Scale Mining for the rich Ghanaians to operate and must be made to comply with local and International standards on Mining etc. Including employment of a qualified Mining Manager, Environmental Manager, Safety Manger, medical elements etc.

Socially; for them to be socially cohesive through actions to inculcate love for each other and networking to ensure Social cohesion.

Inspectionally/ Militarily: There must be the enforcement of the laws to ensure they work appropriately, prevent working at proclaimed no go areas and containment within limits by use of minimum force. Since man is very greedy, rich people and foreigners must not be allowed to operate Small Scale Mining if we really understand what it means. Ghanaian tycoons solely or in partnership with foreigners should work within the proposed Medium Scale Mining Sector with standards same as that for Large Scale Mining Companies but with lower Capital Requirement threshold. So that rich people and foreigners found operating small scale mining are arrested and prosecuted,

Psychologically/ Religiously; Some Small Scale Miners are with the misconception that a loss of blood is an indicative of good omen for their mining activities hence need to inculcate a good mindset thinking including the repercussions of Small Scale Mining.

So, the idea of President Mahama for a Gold Board to deal with the problems of the current Small Scale Mining Sector is very laudable. It will kill with one stone more than two birds like the danger to the environment, danger to Agriculture, the problems of the safety and health of the operators/others. Lastly, it will ensure no hoarding nor smuggling of gold and thus robbing the people of Ghana from obtaining maximum returns from the minerals. Since the people are the owners of the minerals as decreed at Article 257 of the Constitution, the accounting of the gold, the repatriation of export returns and payment of taxes after sales are necessary. Hence, a vehicle to ensure this is very important.

But I am rather of the strong view that a Minerals Board akin to COCOBOD and her operations is the appropriate institution or vehicle to deal with the debacle in the Mining Industry especially with regards to the current state of Small Scale Mining. The Minerals Board will help to ensure Ghana receives maximum returns from her minerals by operators other than the Large Scale Mining Companies who are member Companies of the Ghana Chamber of Mines.

Minerals Board is appropriate since it will cover all minerals including industrial minerals like limestone, Sapphire, Salt from Sodium and Lithium, quartz etc in Ghana, which are all vested in the President on behalf of and in trust for the people of Ghana.

The Minerals Board should either be under the Minerals Commission or independent of it. So if it is by the latter option, then the Minerals Commission will be responsible for matters on Large Scale Mining only. I rather recommend it should be under the Minerals Commission.

Mining is a capital intensive project, so in 2018, as part of measures to control the activities of Small Scale Mining by way of reducing the associated menace to the barest minimum level, I recommended for the establishment of a Medium Scale Mining Sector, so that Ghanaians tycoons like Chairman Wontumi, Nana Toku etc who are interested in mining are navigated from the Small Scale Mining Sector to the Medium Scale Mining Sector.

The establishment of a Medium Scale Mining Sector will enable the Ghanaian tycoons to operate solely or with partnership with foreign investor(s) and comply with local and international standards. I recommend that this should be governed with a new investment law. At this point, let me point a serious blunder in Ghana’s Investment Code as under Ghana Investment Promotion Centre Law 2013 (Act 865), section 27 of GIPC Act 865 of 2013, did not capture Small Scale Mining as no go areas for foreigners as decreed by an Act of Parliament as no go area for foreigners. This should be corrected.

By an Act of Parliament, Small Scale Mining is a no go area for Foreigners for very good reasons including the protection of the environment. Hence, the Registrar of Companies and the Minerals Commission the related Agency acted wrongly by allowing foreigners to operate in the Small Scale Mining Sector in 2012 as Support Services Providers with the enactment of the Minerals and Mining (Support Services Regulations 2012 (LI2174). This contributed greatly to the massive destruction of the environment because Chinese investors brought in thousands of excavators, Chafang machines into Ghana to provide support services to the Small Scale Mining Sector as permitted by Regulations LI2174 of 2012.

Based on inputs from myself and others in 2018, this law that allowed foreigners to provide support services in the Small Scale Mining Sector was repealed in 2019 but we still have foreigners especially Chinese operating in the Small Scale Mining Sector reserved for Ghanaians in the name of providing Support Services. This so because the stable was closed after the horse has bolted away. Unfortunately, the foreigners especially the Chinese ended up or end up to be the owners of the Small Scale Mining Rights, as reserved for and granted to Ghanaians.

So, a Minerals Board should see how to solve the quagmire of the Foreigners especially the thousands of Chinese in our midst with thousands of sophisticated equipment and substantial money for mining activities. This is the reason, I recommended in 2018 for the establishment of a Medium Scale Mining Sector with prescribed minimum capital investment say Five Hundred Thousand US Dollars and maximum capital investment thresholds of 2 Million US Dollars and the levels of equity if there is foreign participation, I recommended two-thirds. I also recommended not more than 7 foreign staff so as create job opportunities for Ghanaians, the employment of a Mining Manager, three Mining Supervisors, three Environmental Officers, three Safety Officers and three Process Plant Operators, two Smelting Officers etc

It is envisaged that most of the foreigners especially some of the Chinese working in our midst do not make contributions to SSNIT, do not pay PAYE and other taxable requirements. One cannot tell whether they have secret banking system, since you scarcely see or meet a Chinese visiting a Bank. Thus, it is envisaged that Ghana is losing a lot of revenue in dollars despite the Chinese are making huge income in Ghana.

So, as stated the proposed Minerals Board should come out with a Medium Scale Mining Sector to officially allow the Chinese to work freely in the Mining Industry and ensure they contribute greatly to national development by financial contributions. It is gratifying to note that the Chinese have made good investment in the Housing Estate Sector and other services.

A Minerals Board should see for the resetting of the monopoly or the exclusive right of Precious Minerals Marketing Company for the exporting of gold and diamond from Small Scale Miners by repealing the aspect of the Mineral’s and Mining Amendment Law 2015 (Act 900) which denied the Precious Minerals Marketing Company from direct exporting of the gold from the Small Scale Miners and gave the responsibility to Private Gold Exporting Companies.

A critical study on the matters of Private Gold Exporting Companies and the story by the CIA and Reuters in 2016 that Ghana made a loss over 3 Billion US Dollars from the Small Scale Mining Sector in 2016, (that is one year) after the enactment of Act 900 of 2015, hence, the first one year of the existence of the Private Gold Export Companies may suggest that Act 900 of 2015 created a looting Scheme for foreigners and Ghanaians. It should be noted that beside the loss of revenue, it is not to interest of Ghana, because greedy foreigners jointly operating Gold Exporting Companies could be fueling the illegal mining activities bedeviled Ghana.

The restoration or resetting of the monopoly of the Precious Minerals Marketing Company and converting it to Minerals Board akin to COCOBOD. It should be noted that Article 257 of the Constitution is very clear with the ownership of the minerals as for the people of Ghana. So no one or organization should be allowed to export gold and diamond from the Small Scale Mining Sector on behalf of the people other than a State Agency. A careful study of Section 2 of Article257 of the Constitution would reveal it seemingly support my position. So establishment of Minerals Board akin to COCOBOD is a better option than a Gold Board.

Small Scale Mining operators and the Operators of the proposed Medium Scale Mining should not be allowed to keep or hoard gold obtained from mining without accounting for it to the State Agencies especially GRA, Bank of Ghana, Precious Minerals Marketing Company ( herein the proposed Minerals Board).

The gold so obtained by Small Scale Miners etc must be sold to the proposed Minerals Board. So the Minerals Board should establish a Mineral Marketing Company to register and license buyers of minerals like gold, diamond etc as the buyers from the Small Scale Miners and the proposed Medium Scale Mining Sector on behalf of the Board and the MMC, so that MMC as subsidiary of the Minerals Board export the gold and bring 100 percent of the sales to Ghana, like what Cocoa Marketing Company (CMC) does in the cocoa industry.

It should be noted from the above narrations that Ghana’s problem in the Mining Sector as well in the general economy of Ghana is self-inflicted, presumably due to a failure to appreciate the history on Small Scale Mining in Ghana, hence lack of understanding of the root causes of a matter otherwise the characteristic of a problem or an enemy coupled with a failure to apply the relevant laws are our problem and the lack the zeal to apply the laws.

. .
So at this junction, it is important to take note of the history of mining in Ghana especially matters on Small Scale Mining for one to appreciate the recommendations for the establishment of Community Small Scale Mining for rural folks, Medium Scale Mining for Ghanaian tycoons to operate solely or with foreign partners. Lastly, the establishment of the Minerals Board for the regulation of both the Community Small Scale Mining and the Medium Scale Mining and for the purchase of the Minerals say gold, rough diamond or salt (lithium or Sodium Chloride) and exporting same. All of these may be good measures to deal with both the environmental hazard and the economy problem caused by smuggling or hoarding of gold from the current Small Scale Mining Sector.

Mining started before the coming of the Colonialists, initially with the Portuguese led by Diego D Azambujah in 1482 and the establishment of the name Elmina, which means the Mine. The first official mine by the earliest Europeans was Marlu Gold Mine in 1895 at Prestea, followed by the Adansi Mine by the three Fanti Brothers from Cape Coast which became Ashanti Gold Company in 1896 and later on it was bought by Cad and others.

Enter the British Colonialists, with their English ( brafo) they termed the traditional mining as Small Scale Mining which was coined in broken English as Galamasey that is Gather and Sell, The British Colonialist or masters banned Small Scale Mining in 1906 but allowed Underground Mining which was beyond the scope of the local Akans. Initially, the Akans were afraid to participate as employees for the underground mining workings due to the mistaken belief or fear that they may encounter their ancestors in the Underground Mines. So people from the North especially Dargetis hence Dargetis were used by the European Miners. Reason for Dargetis Compounds in the old mining areas especially Prestea, Tarkwa and Obuasi.

So, the local Akans were made to concentrate in Cocoa farming to feed Cadbury Cocoa processing plants to produce Buornvita, Ovaltine equivalent to today’s Milo by Uniliver Ltd This led to a boom in the cocoa prices and the price of cocoa became higher than the price of gold, thus the locals were motivated to continue with their farming projects.

But, due to the long gestation period of Cocoa (three years before harvesting from planting otherwise yearly fruiting), some of the farmers continued with the Galamasey operations which gave quicker and ready income as eloquently narrated by the very beautiful Queen Mother of the Ashanti Kingdom, that her grandparents especially one Kwame Danso practiced Galamasey side by side their main farming projects.

The Queen mother narrated this during the Ashanti Regional Forum on Small Scale Mining in 2017 as covered by Joy News which is now part of this TV Station’s narration on the fight against Small Scale Mining. This was part of the previous regime’s National Stakeholders Engagement through the Public Forum to collate ideas and to ginger the people for support for the fight against the debacle with Small Scale Mining.

The ban on Small Scale Mining remained enforced from 1906 era of Gold Coast up to 1986 era of Ghana but the number of participants kept increasing. So in 1986, as part of win-win solution, the regime of the PNDC under the auspices of the World Bank Group and during the Economic Reform Program (ERP) and Structure Adjustment Program (SRP) recognized the indigenous or the time-tested traditional mining locally as Galamasey.

So, Galamasey termed in English as Small Scale Mining was formalized or brought under Official recognition in 1986 with the legalization of Galamasey into Small Scale Mining with the initial passage of Section77 of the Minerals and Mining Act 1986 (PNDCL153), please refer to this law for authentication that Galamasey is Small Scale Mining and nothing more.

As part of the Legalization and Formalization or Regularization of Small Scale Mining, the PNDC in 1989 enacted the Small Scale Gold Mining Law 1989 (PNDC Law 215). It was part of actions to mitigate or alleviate poverty hence it was part of the PMSCAD portfolios established in 1989. So, this law was based on the global characteristics of Small Scale Mining including thousands of rural folks, who saw the gold as a gift from God from them to escape from their poverty miseries. Hence, rural folks’ livelihood project despite the operation has serious implications to the environment and Agric. Thus the originators of the law based on recognition of the dangers of small Scale Mining, gave the clear and strict interpretation of Small Scale Mining at Section 21 as a Mining method without the use of sophisticated technology, without use of substantial amount expenditure, without the use of mercury and that is restricted to only Ghanaians.

The originators of the law also considered mankind as very greedy and may therefore act irresponsibly so the put in place measures for the protection of the environment. The law came with a caveat that Small Scale Mining would only be granted if and only if it is in the interest of the affected community. Thus a small scale miner must be a resident member of the Community and not city dwellers otherwise nonresidents of the area.

Also as part of the formalization of Small Scale Mining the PNDC established the Precious Minerals Marketing Company by the Precious Mineral Marketing Company law 1989 (PNDCL219) to purchase gold from the Small Scale Miners by firstly registering and licensing Precious Minerals Buyers, act as Assay Laboratory for the gold and provide the minerals needs for recognized jewellery makers by selling their gold needs after evaluation and lastly export the gold and bring 100 percent of the sales to Ghana.

President Kofour in 2006 amalgamated all the Mining Laws including the Small Scale Mining Laws into the Minerals and Mining Law 2006 (Act 703) which provided matters on Small Scale Mining from Section 81 to section 99. The Small Scale Mining law in 2006 failed to take notice of the dangers to the environment by likely Small Scale Miners, that is unlike the laws by the PNDC Law 153 0f 1986 and PNDC Law 215 of 1989 especially at section 21 which gave clear interpretation of Small Scale Mining, the new or current law is ambiguous. Hence, it gave room for looting schemes as revealed by several works by seasoned scholars otherwise as the situation on the ground suggests.

Between 2007 and 2008, the regime of President Kofour in order to see to the improvement on small scale mining techniques, sent over 300 Ghanaians to China to learn on how to mine gold. Some of these persons due to the awareness that mining is a very capital expensive, invited their friends from China or some Chinese to come to Ghana through a vehicle of Ghanaian and Chinese friendship association to support them in their small scale mining ventures.

In 2012, the Minerals Commission enacted the Minerals and Mining Regulations 2012 on Support Services (LI2174) and allowed foreigners to enter the Small Scale Mining Sector in the name of provision of Support Services but ended up with some of the Foreigners becoming the owners of the Mining Rights just like the unpleasant history of MTN, with one Mr Aggrey, the Original Holder of the Telecom Right/Franchise that was Spacefon, latter as Areba, who had to go to Court because he was sidelined by his foreign partners during a sales and purchase agreement during the transition from Spacefon to Areba.

A careful study on LI2174 of 2012, would reveal that it was against the parent law on Small Scale Mining that is Small Scale Mining is limited to only Ghanaians. Hence the Parliament of Ghana in 2012, legalized or allowed Foreigners to participate in Small Scale Mining in the name of support services, hence the preponderance of excavators, Chafang machines before 2018 is attributed to this bad Regulation.

This situation made me in 2018 to initiate actions through submissions published in Modern Ghana including a letter to the President on Small Scale Mining which included the need to repeal this bad law which was promoting the use of sophisticated equipment for Small Scale Mining. The President caused the repeal of this law in 2019, but it was too late, since the stable was closed after the horse has bolted away, that is to say the repealed of LI 2174 was after over thousands of excavators and thousands of Chafang machines had been brought between 2012 and 2019.

Chafang machines are floating motorable machines for dredging for gold in rivers or water bodies. So for the preservation of our rivers and water bodies there must be a stoppage of the importation production, selling and usage of Chafang machines in rivers in Ghana.

The above narrations tells why Ghana is not able to deal reduce the menace and the loss of revenue from the Small Scale Mining Sector to the barest level. Hence my take for the Minerals Board.

The Case for Minerals Board
The Minerals Board as proposed in the Mining industry must regulate the Small Scale Mining Sector and the proposed Medium Scale Mining Sector, provide service support to the part of the Mining industry, must register and license Gold Buyers to buy gold from the Small Scale Mining Sector and the proposed Medium Scale Mining Sector on her behalf, manage the purchases by selling some gold to local registered Jewellery makers and export the remaining gold, like what COCONOD does in the Cocoa industry.

Small Scale Mining in Ghana is a serious disaster. This is so because unlike the Colonial masters of Gold Coast regime and regimes of the Heads of States of Republic of Ghana before 2001, the regime of President Kofour and that of subsequent Presidents through the Minerals Commission woefully failed to appreciate that Small Scale Mining was/ is a potential national disaster to the Environment (destruction of the environment) and thus failed to ensure reclamation. Google for the Auditor General Performance Audit Report for 2020 on Small Scale Mining as submitted to Parliament in 2021 and you will weep for Ghana.

Small Scale Mining beside the danger to the Environment, has a very bad effect on the Economy due to effect on Agric, the Cocoa industry and issue of hoarding and smuggling of gold etc. So, one may be right to say that not much critical thinking was done between 2006 and 2024 to ensure to contain the effect of Small Scale Mining, hence the current results is therefore self-inflicted. The global Cobra Effect is hereby referred. Google for the Cobra Effect for how a well-meaning intention or action can backfire and cause problem(s) with relationship or a threat to social cohesion otherwise become an existential threat to mankind as with the case with Small Scale Mining. This therefore speaks volumes that no sufficient critical thinking was done during the makings of the laws on Small Scale Mining. Hence the state of ambiguity.

It must be noted that Small Scale Mining is a necessary evil like a prostitution so it must be kept under control with an eagle eye. Hence my idea of the Cooperative or Community Small Scale Mining for interested rural folks or residents with credible leaders and the activity must receive with the approval of the chief who help the state to monitor and so the leaders and the Chief could held responsible for any mess that is to say contacted to rein in the operators. As well as my idea of Medium Scale Mining for tycoons to operate solely or as joint partnership with foreigners and they are to comply with local and international standards in mining. Lastly, the proposed Minerals Board to act as the regulator and through a subsidiary company should be responsible for the direct export of Gold from both the Community Small Scale Mining area and the proposed Medium Scale Mining area. Thus through the establishment of a Minerals Marketing Company under the Minerals Board, akin to Coco Marketing Company under COCOBOD.

Gold Bullion sales depend on four variables, namely (a). The purity of gold, (b). Impurity content of minerals like silver or copper which is also sold to and paid for by a Gold refinery say Rand Gold Refinery. (c). the weight of gold in troy ounces lastly (d). The World price of a troy ounce of gold, normally provided by London Bullion Marketing Authority (LBMA) as the spot price. So the Board should take note of this.

It must be noted that unlike the State of affairs with the Small Scale Mining, the Gold from Large Scale Mining Companies who are member Companies of the Ghana Chamber of Mines are well accounted for in a very transparent manner to Minerals commission, GRA, Bank of Ghana and to the related Refinery or the Foreign Buyer. This is so, because the processes of gold accounting and weighing are done by at least three people including a Custom Officer from GRA, the Head of Security, the Process Plant Manager and the Gold House’s Supervisor under CCTV Coverage. The weighing is done with at least two highly sensitive weighing scales to ensure same weights. All the Mines under the Ghana Chamber of Mines used almost the same standards for the accounting, and shipment by helicopter. The gold is escorted by both the Ghana Police and a Senior Custom Officer from GRA.

For the avoidance of doubt, let me say again from my work experiences that the Gold is well accounted for in a very transparent manner by the member Companies of the Ghana Chamber of Mines because I was once a very Senior Security Operator of Bogoso Mine and the author of a well prepared or revised Metallurgical Security Codes for the Company which was accepted by Rand Gold Refinery in South Africa and as such made the Refinery to pay for the bullion (gold) on just on receipt of the documents or mail on the details of the gold and the content or details of valuable impurity like silver etc without the physical receipt of the gold which is in transit and covered by Insurance.

This was/is so, since the process are supervised or covered and authenticated by a Senior Custom Officer from GRA who physically covered or covers the analysis and the weighing of the gold, boxing of the gold, sealing of the boxes with gold with both seals of GRA two per box and that of the Company and the details are covered with signatures of the Commercial Manager and the Custom Officer from GRA, and the Refinery acts on the payment without receipt of the gold on receipt of the email normally sent to the Refinery with same email copied to GRA, Bank to Ghana and Minerals Commission. This state of affairs convince them to effect payment before the arrival of the gold.

The Custom Officer and the Head of Security physically ensure the storage and security of the Gold in a Strong Safe with multiple locks with keys and codes kept by different persons including security head, the Manager of the Process Plant. The securing of the Strong Gold House is done with multiple locking systems with keys with different people including the Head of Security, the Process Manager and the Gold House Supervisor.

The final loading of the helicopter for within Ghana’s shipment of the boxes of bullion, and the shipment of the secured bullion with the seal of Custom and the Company’s seal to the Refinery via the Kotoka International Airport are done under armed Police escort.

A Department of the Ghana Chamber of Mine namely Analysis, Research, and Finance normally gives support to PMMC in the revenue assurance mechanism by collecting data from the Mining Companies and submit to PMMC, these include bullion production itineraries of member companies, and does reconciliation of assay reports of the PMMC and that of Refineries of member Companies and resolve any admin challenges. Thus reconciliation between PMMC and Mining Companies is done through the Ghana Chamber Mines on behalf of the Large Scale Mining Companies.

Thus the accounting process and sale of gold by the Large Scale Mining Companies who are Member Companies of the Ghana Chamber of Mines are transparent due to the effective monitoring system by the State, the Buyer of the Gold which is normally by Contract and the Company. So, it is not necessary for a Rep of the proposed Minerals Board to be stationed or assigned to each of the Large Scale Mining Companies under the auspices of the Ghana Chamber of Mines to physically monitor the gold tarnation as part of Probity, Transparency and Accountability Policy.

But the situation with Small Scale Mining is very murky, no transparency and accountability in this sector, hence some small scale miners smuggle out the gold, others hoard the gold at their homes etc. Hence, not the best as narrated above. So a well-established Minerals Board should see to ensure transparency and accountability in the mining sector.

For instance, It was also reported by the CIA and Reuter in 2016 that over 7 billion US Dollars of gold was exported from Ghana in 2016 to the Arab Emirates but only 5 Billion US Dollars from gold sales was brought to Ghana as accounted by Bank of Ghana. Thus 2 Billion US Dollars may be due to retention outside Ghana and or smuggling is loss to the State from the activities of Small Scale Mining.

There is also a problem of holding of the gold for a very long time otherwise hoarding of the gold by Small Scale Miners without accounting to GRA, PMMC, Minerals Commission and Bank of Ghana. In 2016, we were also told of an Aircraft with over 50 Million US Dollars worth of Gold from Ghana was detained by the Airport Security in Dubai in 2016 due to lack of documentations. lastly we saw people displaying gold at homes etc

Furthermore, a research report for the period 2011 and 2017 by scholars including from the Institute of Social and Economic Research (ISSER) Ghana submitted in January 2018 indicated that Ghana lost over 2 Billion US Dollars from no taxes due to undervaluation of gold exports or Gold Sales. Based on this report, the then President of Ghana, President Nana Addo directed appropriate Stakeholders and made Ghana to find an Independent method of verifying gold export in order to ensure Ghana obtains maximum revenue from the precious minerals. This tells that Ghana through the Precious Minerals Marketing Company and Minerals Commission joked with gold accounting before 2018.

So, based on the order from President Nana Addo in January 2018, the related Stakeholders especially the Minerals Commission, Ghana Chamber of Mines, Association of Gold Exporters, Chamber of Bullion Traders, PMMC complied with his directive by supporting the PMMC in the establishment of a modern state of the art laboratory at the Kotoka International Airport with the mandate to physically/directly assay gold earmarked for export from Ghana.

The State’s Assay lab (through PMMC) now has three nondestructive assay equipment namely Ultrasonic Testing Device, Specific Gravity Equipment, and XRF Machine. National Assaying by PMMC actual officially started in February 2018 based on the directive of then President of Ghana Mr Nana Addo. This was indicative that PMMC was just a name, thus explained the state of smuggling or poor accounting of gold in the area of Small Scale Mining before 2018.

With the acquisition of the excellent assay equipment, so as part of the establishment of the Minerals Board, the Minerals Board Act should require all gold from the Small Scale Miners and the proposed Medium Mining Sector as recommended above to sell all their gold to the proposed Minerals Marketing Company under the proposed Minerals Board through registered and licensed Buyers. The sales of the gold to the Agency of the Board should be done within two weeks without holding the gold for very .long nor hoarding it.

For transparency and accountability the proposed Minerals Act should require that the gold should be weighed in the presence of the owner and his Rep with two standard scales which must be calibrated twice in year to ensure no under or over payment

Gold is weighed by either by a Nondestructive method by (a). X-ray Fluorescence (XRF). (b). By Density or Specific gravity Dry and water density. (c). Ultrasonic Testing, otherwise by destructive methods by Cupellation or fire Assay. Gold in Ghana by the Modern Labs is by the nondestructive method. The Assay equipment at a laboratory gives gold purity and the standard weighing scale gives the weight, and the price of the gold is determined using the International market price in Dollars.

The proposed Ghana’s Minerals Board should adopt the Guyana’s Gold Board measures as follows.

The Price given must be higher than what illegal buyers offer and individual agents should have the option to be paid in dollars, 10 percent of the cost in United State Dollars recommended.

The tax on the gold should be as follows; (a) For pure gold which less than 1,100 US Dollars, about 2 percent, when greater than or equal to 1,100 US Dollars but less than 1,300 US Dollars it should be 2.5 percent, if greater than or equal to 1,300 US dollars but less than 1,600 US Dollars 3 percent, Greater than 1,600 about 3.5 percent

The Minerals Board through her proposed subsidiary of Minerals Marketing Company to be responsible for Assaying of the mineral say gold and the gold should be exported by the ICUMS system under close supervision of Bank of Ghana.

The tax regime to be adopted especially for the Medium Scale Mining Sector should include royalties, corporate tax, PAYE by all the Staff both local and expatriate workers, likewise SSNIT contribution.

Repatriation of 80 percent of gold export to Ghana within 30 days, failure to proof repatriation of export proceeds should lead to sanctions include prevention of doing so or revocation of licenses upon persistent breaches and possible prosecution.