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The National Assayer – PMMC’s role in providing revenue assurance to government on gold exports

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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The Prophet part 4

Antobam woke up with a terri­ble headache. He checked the time on his mobile phone, 2:30 am. “What! Where is the money?” He asked aloud. “Where are those girls? Why did I drink so much of that whisky? What were those two girls up to?” He sat up on the bed and noticed a bulge close to the pillow.

He lifted the mattress and picked up the newspaper wrappers with the neatly arranged notes. He saw the neatly written record of the value of the notes. No, those girls are not thieves.

“It was my mistake. If I hadn’t drank myself to sleep they would be here in bed with me, giving me the time of my life. Pretty girls, those two. And so loyal and honest. Tomorrow will be different.”

“I will not drink any whisky, and I will show them that I am a real man. Just then he heard the whis­pers. Very soon it will be time, they seemed to be saying. This is an important day.”

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The gold dealer will bring lots of money. Give him some of the liquid to drink, and we will prepare him. He will do very big business, and he will give you anything you ask for. There will be more miracles and testimonies today.

Antobam smiled to himself. “I am going to be a very rich man in only a few days man. Money, power, and women. Wow! Antobam got to the grounds at 5, but there were quite a number of people waiting.

Mr Kwame Dofu was among them. He greeted them all, and they came around to shake his hand. “My brothers and sisters, I assure you that whatever your problem is, you will not go home without a solu­tion.” Shouts of “Amen” “thank” you Osofo and “you are a true man of God” responded.

“Please take your seats, and start talking to the great one about what­ever bothers you. Before the service is over, there will be a solution.” He waved Mr Dofu over, and went with him to the wooden structure that serves as a temporary office.

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“My brother, I have done quite a lot of work on the issue you came to see me about. I have prepared a special, powerful package for you. Take this, drink it, and go back to your business. I want to see you in two weeks.”

Beaming with smiles, Mr Dofu drank the foul smelling liquid in two gulps, said a big thank you to Anto­bam and took his leave. “I believe you, Papa Osofo. And I assure you that I will reward you, big time.”

Just when Osofo Antubam finished with Mr Dofu, Mary and Suzzie went over to him. “Good Morning ladies. I am very sorry about yesterday. I drank too much of the stuff you gave me. Today will be different, I assure you.”

“Don’t worry, Osofo. Since you are now setting things up, our main concern now is to help you to put things in place, and to make you comfortable. We are always there to serve you. This morning, Osofo, we want to go and clean up your place, and prepare something nice for you when you close.

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And before coming to church, we will pass by the bank and collect the forms. After you have signed them, the account will be open. You can check the payments anytime and, of course, issue cheques whenever you need money.”

“Suzzie and Mary, I am happy I picked the two of you from the very start. Listen, I will take good care of you, okay? Here is some money. Buy whatever you need for the er­rands you have mentioned.

And here is the key. Please come back as early as you can. You know I need you here.” The service was very lively. The lively singing of praise songs was followed by one and a half hours of testimonies.

Most of them related to money – big sales, new jobs and overdue debts paid. But there were also testimonies about healing. Barren women had taken seed, and, of course, several men who had lost their bedroom authority had re­gained them, to the delight of their partners.

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As he had promised, Antobam preached for only 30 minutes, ex­horting the congregation to attend church regularly, pay their tithes and offerings, and strictly follow his ‘directions’ for securing solutions to their problems.

After another round of prais­es during which the congregation danced to the floor to drop their offering, he closed the service, grabbed the big bowl which was full to the brim with money, and moved to his desk. A long queue was quick­ly formed at the desk.

Meanwhile, Mary and Suzzie had gone to give Antobam’s place quite a decent look. A new bedsheet and pillows, a secondhand carpet and four plastic chairs placed in the verandah had done the trick.

They also prepared two fish and chicken stews. After all these, they rushed to the National Savings Bank and collected application forms for opening current and savings ac­counts.

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They joined the service a few minutes before the main session closed. Antobam looked round and saw, to his relief, Mary and Suzzie moving towards him. “Hello ladies. What have you been up to?” “Quite a bit, Osofo. We’ve just collected your drink. Here you are. We’ve made a few changes at your place. I think you will like it. You will also have something nice to eat. Now, here are the forms for the savings and current accounts.

If you will sign them, the bank will open the account. From today, we can pay all monies direct into the account.” ‘How can I thank you, ladies?” “You don’t need to thank us,” Suzzie said. “It is our duty to help a man of God succeed.” “Okay, my ladies, please take the offerings and count them as you did yester­day.

You can add the payments made after the consultations. Will it be possible to pay them into the account today?” “Yes,” Mary said. “The bank closes at four. If we leave here at three, we would be there just in time.”

The two friends started counting, as Osofo Antobam gave his clients his directions for solving their prob­lems. On quite a few occasions he closed his eyes as if he was receiv­ing direction from above on what to do.

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But as the fetish priest at the Nana Kofi Broni shrine and the dwarfs had assured him, the solu­tions would certainly be provided. Having heard the huge testimonies earlier in the day, the clients parted with substantial sums of money in expectation.

By Ekow de Heer

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The issue of spiritual father in our churches

 A student was supposed to go to school as the natural cause of events should be when universities or schools in general opens but this was not the case in a certain young man’s life.

He decided to postpone his trip because apparently he could not get to meet his pastor, his spiritual father. The question is, should this spiritual father die, will the young man’s life come to an end?

Does it mean in such an instance, he is going to curtail his education? This is a wor­rying trend in a lot of church­es where the pastors use this notion of spiritual father to manipulate members espe­cially the youth.

Some unscrupulous pastors utilise this spiritual father concept to have affairs with gullible young ladies in their churches.

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Now with homosexuality gradually making inroads into some of the churches, young men are becoming vulnerable to pastors who have hidden homosexual inclinations.

This spiritual father con­cept is a Biblical concept that runs through both the Old Testament as well as the New Testament. We see it in 2 Kings 4:12 where Gehazi is serving Elisha and also in the New Testament we see Paul relating to Timothy in 1 Timo­thy 1:2 as a Spiritual Father.

In fact, the concept of spiritual father is a good thing if executed according to the word of God since it helps in guiding the younger ones. However, it becomes prob­lematic when it is being exe­cuted by unscrupulous wolves in sheepskins as described by Jesus in Mathew 7:15.

I see it as a way that these unscrupulous so-called men of God maintain their hold on the congregants so they do not question their unchristian actions.

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One of the things I have observed since I got born again many years ago is that, any pastor who often insists that members recognise that he is their spiritual father is a warning sign that he is doing some wrong things or is about to indulge in some wrong things.

A parent complained about how his daughter was being influenced by a pastor of the church she attends and how worried he was. I am sure there are many parents out there with stories to tell about how their wards are be­ing made to see their pastors almost like their Jesus.

These pastors have man­aged to make their congre­gants so loyal to them and to believe in them so much that it is terrifying, as a parent.

The way things are going, an immediate intervention is required otherwise I am not a prophet of doom but I forsee unfortunate instances where parents burst into church auditoriums and star shooting some Pastors out of frustra­tion and anger.

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We cannot look on uncon­cerned as a society and allow unscrupulous fraudsters using the name of God to create problems for families. My recommendation is for a cer­tain amount of regulation in order to bring some sanity in religious practices.

I agree that ordinarily regulating religious practices makes it a bit restrictive in terms of freedom of worship as enshrined in our constitu­tion but given the way things are going, a bit of regulation will not be out of place.

Disgusting stuff are being attributed to some men of God. There are cases of ma­nipulation of young ladies and sometimes married women by so called men of God and it is bringing Christianity and therefore the name of the Lord into disrepute.

Christianity is gradually losing its attractiveness as a result of the negative report­age resulting from disgusting stuff happening in Christian circles. The way some pas­tors have been manipulating congregants to take money from them leaves much to be desired to the point where they are convincing some of the youth to give out their phones. May God help us.

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By Laud Kissi-Mensah 

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