Wed, 11 Nov 2026 Feature Article

When Your Money Is Your Money: Why the Bank of Ghana's Merchant Funds Directive Matters

Every day in Ghana, a woman selling provisions in Kasoa, a young man running an online clothing store in Kumasi, and a restaurant owner in Osu accept payments by mobile money, card, or payment link. The customer pays, the screen says “successful,” and the trader believes the matter is closed.

But between that payment and the merchant’s bank account sits a quiet middleman: the Payment Service Provider (PSP). Until now, many Ghanaians never asked a simple question: Where does my money sit while it waits to reach me?

The Bank of Ghana has now answered that question, and I believe the answer deserves applause.

What the Bank of Ghana Has Said

On November 6, 2026, the central bank issued Notice No. BG/GOV/SEC/43 to all Payment Service Providers and Settlement Banks on the management of merchant collection funds under Section 101 of the Payment Systems and Services Act, 2019 (Act 987).

The notice was signed by the Secretary of the Bank, Aimee Vyda Quashie, and has been widely reported this week.

In plain language, the directive says the following:

Money collected on behalf of merchants must be credited into a designated settlement account and must not be mixed with the PSP’s own operational funds.
PSPs must pay merchants into their designated bank accounts strictly according to the settlement period agreed in their Service Level Agreement (SLA).
The Bank of Ghana reminded PSPs that they are licensed to facilitate payments, not to take deposits. They may not hold, use, pledge, or exercise ownership rights over merchant funds. The money remains the property of the merchant until settlement is completed.
A PSP may not withdraw, transfer, pledge, place a lien on, or set off debts against money in the settlement account. The only permitted transactions are payments to merchants and legitimate fees earned by the PSP.
Settlement banks must manage these accounts solely for settlement purposes. They must not allow PSPs to use the funds for operations, financing, investments, or any activity unrelated to merchant settlement.
Both PSPs and settlement banks must maintain records, controls, and audit trails that demonstrate the funds are safeguarded, segregated, and settled on time. The Bank of Ghana may also require settlement banks to provide statements on these accounts.
Failure to comply is a breach of the regulatory framework and may result in regulatory, supervisory, and enforcement action. All affected institutions have been instructed to act immediately and review their agreements and internal controls.

Why This Is Good News for the Small Trader

Let us be honest about how business works.
A trader’s cash flow is their oxygen.
If a PSP holds merchant funds for three days and uses that money to pay its own expenses, finance expansion, or cover shortfalls elsewhere, the merchant is effectively extending a free loan without ever agreeing to it.

For a large company, delayed settlement may be an inconvenience.

For a small trader who needs to restock tomorrow morning, it can be the difference between remaining open and shutting the business for a day.

By explicitly stating that merchant funds remain the property of the merchant until settlement, the Bank of Ghana has elevated what may have been an industry expectation into a clear regulatory principle.

The directive also protects something even larger than any individual merchant: public trust in digital payments.

Ghana has spent years encouraging citizens to move away from cash and embrace mobile money, QR codes, payment links, and e-commerce transactions.

That trust is fragile.
One major scandal can undo years of progress.

The Warning We Should Not Ignore

We do not need to look far to understand why safeguards matter.

In July 2026, the Bank of Ghana revoked the Dedicated Electronic Money Issuer licence of Zeepay Ghana Ltd, one of the country’s most prominent fintech companies.

The central bank stated that the company had issued electronic money without sufficient cash backing, resulting in a negative variance, and failed to comply with directives requiring it to inject funds to cover electronic money balances owed to customers, agents, and merchants.

Affected wallet holders, agents, and merchants were directed to seek assistance from the Bank of Ghana.

To be fair, the new notice does not state that it was issued because of that case, and I do not suggest that it was.

The Zeepay matter concerned electronic-money backing, while the November directive addresses merchant collection funds.

However, both situations point to the same lesson: when customer and merchant funds are not properly ring-fenced, ordinary people bear the risk.

Prevention is always cheaper than rescue.

Where the Directive Needs More Clarity

A good policy can still be undermined by weak implementation.

1. The Penalties Remain Unclear

The notice refers to “appropriate regulatory, supervisory and enforcement actions,” but, based on reported summaries of the directive, no specific fines or timelines have been publicly detailed.

Rules without clearly understood consequences can be ignored by the negligent and questioned by the compliant.

2. Enforcement Depends on Settlement Banks

Settlement banks have now become important gatekeepers.

The Bank of Ghana has the authority to request statements from them, but that authority will only matter if it is exercised consistently and proactively rather than after problems have already emerged.

3. Small Merchants Have Limited Bargaining Power

Settlement timelines are determined by agreements between PSPs and merchants.

While contractual flexibility has advantages, many small businesses do not have the legal expertise or negotiating leverage to influence those terms.

Most simply click “accept.”
The Bank of Ghana should consider issuing guidance on what constitutes a fair and reasonable settlement period so that “agreed” does not become a euphemism for “take it or leave it.”

4. Costs Could Rise

Some PSPs may have relied on float income generated from temporarily holding merchant funds.

If that revenue source disappears, some providers may respond by increasing service charges.

If that happens, merchants should insist on transparency.

A clearly stated fee is better than a hidden risk.

What Should Happen Next?

PSPs should immediately review their SLAs, account structures, and internal controls rather than waiting for regulatory intervention.
Settlement banks should treat the settlement-only requirement as a firm obligation, not a recommendation, and be prepared to provide records when requested.
The Bank of Ghana should publish detailed guidance on penalties and timelines and consider creating a simple reporting channel for merchants experiencing delayed settlements.
Merchants should review their agreements, ask where their collected funds are held, confirm settlement timelines in writing, and document any delays.
Ordinary Ghanaians should remember that regulations are only effective when citizens expect compliance and demand accountability.

A Final Word

Digital payments are not just technology.
They are a promise.
The promise is that when you earn money, it reaches you in full and on time.

The Bank of Ghana has reminded the industry that this promise is not merely good practice; it is a regulatory obligation.

Now comes the harder part: ensuring that the promise is kept.

When merchants can trust that their money belongs to them from the moment a customer pays, businesses gain the certainty they need to plan, invest, and grow.

And when our money is truly our money, our businesses can finally grow on solid ground.

Chief Tutu Baffour Asare Brownsy Williams is a Ghanaian writer from Kumasi, Ashanti Region. Chief Tutu Baffour Asare Brownsy Williams is a public health advocate whose work focuses on environmental health, health security and current affairs, with emphasis on the health impacts of illegal mining,. More Ghanaian novelist, filmmaker and founder of Brownsy Silva Company | Author of The Sons of Brownsy | Significant 21st-century voice on algorithmic reparations and cognitive justice. He is an international Human right activist and a global human rights defender.

*Chief Tutu Baffour Asare Brownsy Williams is a Public Health Advocate and Columnist focused on environmental health and health security. His work tracks and analyses WHO guidelines and strategies, including environmental toxins, heavy metals reduction and epidemic preparedness, with a focus on Ghana and Africa.*

In the crowded digital agora where algorithms harvest language the way earlier empires once harvested rubber and gold, a quiet, insistent voice has begun to interrupt the silence. Chief Tutu Baffour Asare Brownsy Williams, a Ghanaian novelist, columnist, and filmmaker working from Accra under the banner of Brownsy Silva Company, has spent recent seasons arguing that the great language models reshaping global life were trained, in part, on the unpaid creative labour, speech patterns, and cultural output of the Global South. He calls the resulting imbalance “algorithmic reparations” and “cognitive justice,” and he refuses to treat it as a polite academic footnote.

Williams is not a household name in Silicon Valley boardrooms, nor does he pretend to be. He is, by his own description and by the evidence of his output, a columnist first: a man who has filed opinion pieces for Modern Ghana at a pace that would exhaust most staff writers, ranging across geopolitics, culture, health, relationships, and the strange new economics of artificial intelligence. Beneath the journalism sits a larger architectural project. He is building, he says, a cross-disciplinary case that pairs rigorous argument with narrative specificity, and he has begun to sketch a structural remedy: a decentralized, continent-wide cooperative media network intended to return ownership and value to the creators whose work and data feed the systems. The proposal is deliberately ambitious. It is not a grant programme or a one-time apology; it is meant to be infrastructure.

Born and raised in Ghana, Williams came to storytelling early. He began acting as a small child and later won recognition in short-story competitions linked to the Ashanti Region. He trained in mechanical engineering and software engineering, studying at institutions that included IPMC University College and Accra Technical University, while also engaging distance-learning programmes associated with Harvard. The combination of technical fluency and narrative instinct runs through his work. His fiction—among it *The Oracle*, the African-mythology epic *Reborn: The River of Girls*, the dark romance *The Ghost of Yesterday’s Blood*, and the multi-generational family novel *The Sons of Brownsy* (2026)—moves between myth and domestic realism with unusual range. *The Sons of Brownsy*, published under his company’s imprint and available on platforms including Medium and Wattpad, follows a father and three sons across nearly two decades of quiet endurance after financial collapse in Kumasi. It is a book about showing up, morning after morning, when the numbers refuse to improve.

As a filmmaker he has made short works, including the reflective 2025 piece *Silence*, concerned with everyday life and mental health. Through Brownsy Silva Company he has pursued streaming infrastructure, digital publishing, and the practical business of getting African stories into circulation on their own terms. Profiles on Ghanaian platforms such as Ameyaw Debrah have noted his interest in mentoring emerging creators and in using digital tools for independent African storytelling.

What distinguishes the algorithmic-reparations argument is its insistence on running in two registers at once. Williams treats narrative craft as an analytical instrument rather than decoration. Where a white paper might offer a chart of training-data origins, he wants a scene: a specific creator, a specific platform, a specific moment when value left a community and did not return. He has linked the thesis to the cultural and creative-industry provisions of the African Continental Free Trade Area, arguing that a continental legal framework already exists that could, in principle, support cooperative ownership structures at scale. Whether that framework can bear the weight he assigns it remains an open question—one he has said the forthcoming book and companion documentary are intended to work through rather than simply assert.

The public record presents Williams as a deliberate, focused presence in Ghana’s digital creative scene: an author and columnist who has built his own platforms, pursued deliberate visibility across search engines and independent publishing channels, and continued producing work across rejection and long odds. Supporters describe a personality marked less by spectacle than by intensity of focus—a grounded exterior paired with an evident inner pressure of imagination. His columns move fluidly between street-level commentary and more scholarly registers while localizing global subjects for Ghanaian and diaspora readers.

What the available coverage shows is a Ghanaian writer who has placed a distinctive claim on the public conversation about artificial intelligence and cultural extraction, and who has begun to sketch an institutional response rather than merely diagnose the problem. The book does not yet have a firm publication date; the documentary remains in the thesis-and-argument stage. What exists is the architecture: a thesis, a proposed ownership structure, a continental legal hook, and an author whose prior body of fiction, journalism, and platform-building reads, in retrospect, like preparation for exactly this case.

Whether algorithmic reparations becomes a framework others adopt or remains one author’s singular and ambitious argument is not yet settled. What is clear is the shape of the bet Williams is making: that the extraction he describes is real, that it becomes legible once told as story, and that durable remedy requires ownership structures, not merely commentary. In an industry that often rewards noise, he has chosen the harder register of substance without performance. The ledger, he insists, remains open.Column: Tutu Baffour Brownsy Williams

Disclaimer: "The views expressed in this article are the author’s own and do not necessarily reflect ModernGhana official position. ModernGhana will not be responsible or liable for any inaccurate or incorrect statements in the contributions or columns here." Follow our WhatsApp channel for meaningful stories picked for your day.

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