The association, in a statement signed by Mr Samson Asaki Awingobit, the Executive Secretary, commended GoldBod for progress made in formalising the gold trade, improving traceability, and strengthening Ghana’s external reserves through structured gold inflows, noting that these reforms were beginning to yield measurable macroeconomic benefits.
It, however, expressed concern that certain operational practices were increasingly constraining the activities of licensed self-financing gold aggregators and exporters.
It stated that GoldBod, which was instituted primarily as a regulatory and oversight authority to curb illicit gold exports, particularly within the artisanal and small-scale mining (ASM) sector, was now perceived as both regulator and market participant.
The IEAG noted that such dual roles created a structural conflict of interest, as the regulator was simultaneously setting rules, enforcing compliance, and competing commercially within the same market space.

The association likened the arrangement to a scenario where the Bank of Ghana, as a regulator, would compete directly with commercial banks, stressing that this would be untenable due to the regulator’s access to capital, information, and regulatory leverage.
IEAG noted that although more than 200 gold aggregators had reportedly been licensed, only a small number were said to operate with direct financial backing linked to GoldBod and the Bank of Ghana, including interest-free or concessionary financing arrangements.

In contrast, self-financing aggregators relied on commercial bank funding at prevailing market interest rates, which remain high, creating what the association described as systemic financial asymmetry that rendered many private aggregators commercially unviable.
It said members of the association further reported that GoldBod-backed aggregators were increasingly sourcing gold independently rather than coordinating through licensed private exporters, effectively competing with them.

IEAG also raised concerns over prolonged due diligence and Know Your Customer (KYC) approval timelines for off-takers working with self-financing aggregators, stating that some operators had waited several months for export clearance despite meeting statutory and traceability requirements.
It warned that open-ended and discretionary approval processes introduced uncertainty, elevated transaction risk, and undermined contract enforceability in international commodity markets, potentially resulting in lost contracts and foregone foreign exchange inflows.

To address these concerns, IEAG proposed the adoption of a risk-based supervisory framework consistent with international best practices in commodity regulation, adding that under such a system, off-takers assessed as high risk would not be excluded outright but required to deposit prescribed collateral or the full transactional value into a designated escrow account at the Bank of Ghana.
It explained that this approach would mitigate compliance risks while maintaining liquidity, investor confidence, and competitive neutrality in the market.
IEAG also expressed concern over reports that export proceeds of self-financing aggregators were retained for extended periods in accounts linked to GoldBod or the Bank of Ghana before being released, noting that prolonged retention of funds imposed severe liquidity constraints in a capital-intensive sector where working capital cycles were critical.

The association further cautioned that sidelining compliant exporters could narrow the tax base and weaken long-term domestic revenue mobilisation within the gold value chain, reiterating that GoldBod should focus strictly on its regulatory and supervisory mandate and refrain from direct participation in gold buying and exporting.
It called on GoldBod and relevant state institutions to clearly separate regulatory oversight from commercial activity, adopt a risk-based and non-discretionary approval system, implement escrow-based safeguards, accelerate clearance timelines with defined benchmarks, and review export-proceeds retention practices in line with global trade finance norms.

It added that Ghana’s gold sector is best served by strong regulation that enables markets, not one that substitutes for them, indicating that it remained ready to engage constructively with GoldBod, the Bank of Ghana, and other stakeholders to promote inclusivity and sustainable growth.