Home Business Activate PAAR for customs management – Isaac Adongo to GRA

Activate PAAR for customs management – Isaac Adongo to GRA

Isaac Adongo

Member of Parliament (MP) for Bolgatanga Central, Hon. Isaac Adongo has called on the GRA to, as a matter of urgency activate the PAAR for customs management introduced by Wes Blue Consult for importers to submit all the pre-arrival documents for the customs procedures to be applied to all imports.

This, he said will help address the arbitrary application of advance ruling and create a level playing field for all importers to use the Pre-Arrival Assessment Regime for determining preliminary customs classification and value ahead of shipment of cargo and valued by the various risks management tools at the disposable of customs on arrival and clearance of cargo.

“Where the Pre-Arrival Assessment regimes throw out doubts, under invoicing and manipulations, customs may trigger the application of the Commissioner’s valuation procedures or resort to the sanctions regime under the section 123 of the customs Act”


Below is his full Presentation:







The Centre for Social Justice, an economic and socio-political Think Tank and CSO has created the Leadership Dialogue Series to assist in the discourse on topical issues of national interest. It also gathers expert opinions/views, relevant data and information on national development through expert’s engagements. Today’s event is the 11th in the Leadership Dialogue Series aimed at taking stock of Ghana’s economic crisis with a view to finding solutions for transformation of the economy.

The rationale for undertaking the analysis is to diagnose Ghana’s economic situation before and after the outbreak of Covid-19 and the Russia-Ukraine war to establish the causes of the current economic crisis and identify the hard choices and policies that can assist the country to deal with the crisis and the path to the medium to long term transformation of the economy to build a modern resilient economy. Ghanaians will notice that in recent times some policy-makers and social commentators have looked to the Covid-19 pandemic and the recent Russia-Ukraine war as the main cause of the ills of the Ghanaian economy. It is therefore important for today’s leadership Dialogue series to dispassionately undertake an ex-ante and ex-post performance of the Ghanaian economy using key macroeconomic data from the performance of fiscal policy, monetary policy, external sustainability and financial stability to determine whether Ghana’s economy is a victim of the Covid-19 pandemic, Russian-Ukraine was or pre-existing vulnerable underlying conditions and establish the true causes of the economic crisis and find workable and enduring transformational solutions . In our Vice President’s own commonly used adage “if you disagree, bring your data”.

Ghana’s economy is facing monumental crisis with heightened and unsustainable multiple fiscal risks. Bloomberg recently posited that ‘Ghana’s fiscal wings have been clipped’. Ghana is facing a debt crisis with a debt to GDP estimated at 83% at the end of 2021 (Bloomberg), debt service to total revenue at 129% of total revenue at end of 2020 (IMF), excessive budget rigidities with debt service as the singular most damaging fiscal burden, followed by compensation of employees and statutory payments amidst low revenue generation.

Monetary policy has lost credibility with key policy failures to stem price developments such as spiking interest rates, record high inflation and depreciation of the cedi. We are caught up in fiscal and monetary policy quagmire as fiscal authority and monetary policy have connived against the economy to create mounting fiscal dominance over monetary policy. Inflation targeting framework of the BoG and subsequent management of inflation expectation is not only unanchored but completely thrown to the dogs. Contrary to the believe pf Ghanaians that the Government only borrowed Ghc10 billion from the Bank of Ghana to finance the budget during the covid 19 in 2020, the 2021 annual debt management report makes a shocking revelation. The total exposure BoG to Government of Ghana as at the end of 2021 was in excess of Ghc35 billion with a further Ghc22 billion as at June 2022. This brings the total Government borrowing from the BoG to about Ghc57 billion at the end of June 2022. This illegal and explains why monetary is not credible in tackling price developments.
The result of this illegal fiscal and monetary policy collusion are debilitating high interest rates that is now hurting Government finances, real sector of the economy as the private sector struggles to raise credit to survive and grow the economy, deteriorating living conditions of Ghanaians resulting from loss of purchasing power and erosion of capital of business.
It is on the basis of this that the theme for the occasion ‘Transforming Ghana’s Economy- Scape Goats, Real Causes and Hard Choices is apt and commendable.

Fiscal Developments (2016 to 2024)
There is the need to take a critical look at fiscal developments and how it has impacted the capacity of the country to invest in infrastructure, address or worsen rigidities in the budget and the key drivers of fiscal risks and sustainability.

Over the last couple of years, the mounting fiscal risks to the economy has largely been driven by the high proportion of tax and total revenue used to pay for compensation, debt service and statutory payments. By the end of 2019, debt service alone was consuming about 91% of total tax revenue with only a paltry 9% left to finance the rest of the budget. This means that to adequately meet the full costs of non-discretionary expenditure, the Government had to elevate the public sector debt by borrowing to pay for part of debt service, compensation of employees and statutory payments. Goods and services and capital expenditure have to be financed essentially by borrowing
In the face of lower revenues, this fiscal trajectory as at 2019 was unsustainable and exposed the country to depletion of fiscal buffers to withstand headwinds such as was experienced with Covid-19 and the Russia-Ukraine war.

These susceptible underlying conditions made it very easy for the economy to come under severe strain on the onset of covid 19 and later the ravages of the Russia-Ukraine War. The IMF article IV consultation for 2020 showed that Ghana had zero cash at the end of 2019 to draw on in 2020 to fight covid and actually grew cash buffers of some 1.4% of GDP in 2020 from covid-19 resources

Dwindling Capital Expenditure
The generic measure of the contribution of various factors of production located within a country to the output produced at any given time is its GD‘P, both at the nominal level as well as the rate of growth. So, at any given time, it is expected that factors within Agriculture sector, Industrial sector, and the Services sector of the Ghanaian economy will contribute to the production of a given level of output. However, the commercial production of oil in Ghana since 2011 resulted in the disaggregation of our GDP into oil and non-oil GDP. The oil sector in most cases is considered an enclave, hence may not depict the real performance of general economic activities.
In my discussions of growth as it has always been presented in most empirical literature, let me state emphatically that it is investment that creates Output and growth. By way of data, I will carefully analyse and examine trends in government investment expenditure (capital expenditure) and relate that to GDP growth from 2015 to date as well as the medium-term projections.

Ghana experienced a drastic drop in capital expenditure from 4.5% of GDP in 206 to 1.8% in 2019, reflecting deterioration in infrastructure renewal and development to support sustainable grow.

Figure 1: Trend in GDP Growth vrs Capital Expenditure

Source: Ghana Statistical Service & Ministry of Finance

Figure 1 clearly depicts the trend in GDP growth and investment expenditure from 2014 through to 2021 and the forecast for 2022 and the medium term. In growth accounting, lags and lead effects play an important role in explaining the main drivers of growth. These two concepts help economist explain why “A seed does not geminate the very day it is sown no matter how many times you water it”.

From figure 1 above, the highest peak in capital expenditure was recorded between 2014 and 2016, however, economic growth was relatively modest around that time. Growth peaked in 2017, driven largely by the investment made in the past (earlier before 2017). Ghanaians will recall that huge investments were made by the John Mahama Administration to transform the face of infrastructure. The seeds sown in that time is what yielded growth in 2017. Power was handed over to this current administration right in 2017. Before they could put the necessary government machinery and start initiating policies that will translate into any meaningful economic growth the economy was already bearing fruits from the seeds sown by H.E John Dramani Mahama from 2014 to 2016.

The rebound of world commodity prices and a return to oil production after solving the turret bearing problems in the jubilee fields together with the onset of a return to stable power supply resulted in remarkable growth in oil GDP and in particular recovery of non-oil GDP.

Ghana was poised to unleash further growth in subsequent years if the trajectory of improved investments to address Ghana’s infrastructure gap necessary to eliminate lack of competitiveness and create the enabling environment for the private sector was sustained.

Ladies and Gentlemen, the declining investment in capital projects and its projected steep deterioration is a major cause for concern. As a country grows and expands with increasing population, new settlements and urbanisation, the need to invest significant proportion of the national cake becomes paramount. For purposes of renewal of existing infrastructure and providing additional ones such as roads, schools, hospitals, energy etc. ought to be measured in relation to the size of the economy to provide the appropriate capacity of the economy to renew, sustain and create further opportunities for enhanced.

A reduction in the proportion of the economy to fund infrastructure will ultimately compromise future growth outlook of the country, worsen infrastructure deficits, collapse social services such as health care, education and security and create further unemployment.
Ladies and Gentlemen, no wonder our educational system is in a mess, health care still reliant on the facilities inherited by the administration in the face of mounting pressure on these inadequate facilities, poorly resourced security services leading to the citizenry living in insecurity.

Ghana after experiencing alignment of capital expenditure in response to the needs of the expanding economy from 2014 to 2016 was poised for a sustained take off. Unfortunately, this forward match was to be rudely curtailed in response to the implementation of propaganda policies that were derived from the propaganda lectures of H.E Dr Mahmoud Bawumia that became the trust of the NPP manifesto going into the 2016 elections.

As a matter of fact, I had warned the NPP Government in 2017 that one could be forgiven for delivering series of propaganda lectures and allow these lectures to metamorphose into your manifesto but if you allow these propaganda lectures no matter how eloquently and confidently they were delivered to become Government Policies, implementation will expose you.

Ladies and Gentlemen, the famous policy of moving the economy from taxation to production died a still birth. One village one dam is an example of a reckless waste of public resources whilst one district one factory that was touted as the panacea to Ghana’s industrial revolution became a ruse.

After 2016, investment expenditure continued to decline from 2017 through to 2019, attaining its Lowest dip in 2018. The figure above is self-explanatory and I am sure my audience are left wondering what policies the government was putting in place to transform and grow the economy apart from being fixated with sloganeering and getting busy with unsustainable policy announcements.
My first big question is whether the weak economic growth in 2020 is entirely the result of susceptible pre-existing economic conditions or purely the result of the impact of Covid-19?

I am sure Ghanaians can answer for themselves. Again, it can be inferred from Figure 1 that investment expenditure is projected to decline after 2020. We are right to conclude that the medium-term growth projections cannot be trusted.

Fiscal Developments (2016 to 2024)
Before I delve into detailed discussions of revenue, expenditure and the overall fiscal performance, let me highlight some ills that have bedevilled Ghana’s public finances that provided the signals that Ghana’s fiscal environment was facing heightened risks and was heading towards unsustainable territory.

By 2018, the Government abandoned the pursuit of high revenue generation and began to securitise revenues to support current expenditures. This created further rigidities in the budget and undermined fiscal sustainability. In some cases, unconventional reporting methods were used to hide the true fiscal impact of expenditures as well as debt sustainability. Some of these issues have become very topical in recent times and have been extensively discussed and also drawn the attention of our development partners such as the IMF and World Bank. Amongst them are:
The securitisation of Getfund proceeds for 10 years has resulted Getfund spending an average of Ghc1billion a year to service debt; That of securitisation of ESLA proceeds for 7 years to raise debts have led to the payment of an average of GhcGhc1 billion and some Ghc32 million to friends and cronies in fees and commissions.
These unsustainable fiscal manoeuvres that showed that Government was in trouble stated way back in 2018 and long before covid-19.

Get fund now has a debt of $1.5 billion and ESLA some Gh10 billion sitting on their books and not reported in the public debt though revenues in the budget are used to pay about Ghc2 billion a year in interest on these debts.
Accumulation of arrears due contractors.

This is affecting the flow of liquidity within the banking system because contractors can’t repay their loans, and therefore the cycle continuous. I may be right if I attribute the supposed banking crises to the failure of government to pay contractors who were owed in excess of GHC5.7 billion. As at the end of 2020, both road and non-road arrears was estimated at some staggering GH8.2 billion. As a requirement of the stringent rules of IFRS9, banks are likely going to write of GHc8.2 billion from their capital in addition to the numerous loans they were compelled by Covid-19 and Bank of Ghana directives to restructure. This practice with its non-transparent disclosure of arrears since 2018 has led to Government arrears to contractors and service providers standing at about 7% of GDP (approximately GHc35 billion). The mounting NPL of banks is testament to this predicament.

Using factoring arrangement with commercial banks to pay contractors. At the time contractors needed funds to support their businesses, they were compelled by Government to enter an agreement with Fidelity Bank and the monies owed them were paid a discount ranging between 10% and 14%. This was a clear strategy to take these monies from contractors against their wish. This arrangement which led to payment of an estimated Ghc5 billion is clearly unconventional since the expenditures are processed and paid by bypassing the GIFMIS system, thereby suppressing Government expenditure arrears clearance.

Poor revenue generation and malpractices in revenue generation have bedevilled Ghana’s fiscal policy implementation. Among some of the revenue administration underhand dealings are illegal and deliberate application of customs advance ruling procedures with rudimentary and self-seeking procedures and weak suspense regime. The country has lost huge revenue to these practices.

The Customs Act makes transaction value as the principal method of customs valuation supplemented by policies, directives and statutory compliance with international trade and customs obligations such as the application of WTO policies and procedures and Ecowas common tariffs arranged through the harmonised codes.

Customs advance ruling allows importers to make application to the Commissioner General of Ghana Revenue Authority in advance of shipment of cargo to assist with appropriate classification, determination of origin of consignment as well as the true transaction values of the shipment.

The commission general may grant, modify or reject the application in accordance with the elaborate provisions of section 12 of the customs Act. The customs procedures applied by the Commissioner General in deciding on advance ruling must comply strictly with section 68 of the Act. In particular, the prohibitions provided for under section 68(5) must be strictly complied.

Among others, section 68 (5) (f) prohibits the use of minimum custom values (Benchmark values) in the valuation of imports.

In recent years, the Commission General has been perpetuating illegality by using minimum custom values (Benchmark Values in custom valuation of imports contrary to section 68(5)(f) of the customs Act and also illegally granted discounts on same illegal values to applicants of advance ruling.

The GRA must as a matter of urgency activate the PAAR for customs management introduced by Wes Blue Consult for importers to submit all the pre-arrival documents for the customs procedures to be applied to all imports. This will help address the arbitrary application of advance ruling and create a level playing field for all importers to use the Pre-Arrival Assessment Regime for determining preliminary customs classification and value ahead of shipment of cargo and valued by the various risks management tools at the disposable of customs on arrival and clearance of cargo.

Where the Pre-Arrival Assessment regimes throw out doubts, under invoicing and manipulations, customs may trigger the application of the Commissioner’s valuation procedures or resort to the sanctions regime under the section 123 of the customs Act,

The Commissioner must henceforth cease the use of minimum customs values or benchmark values in customs valuation and build appropriate and workable systems to use transactions values for customs valuation or seek appropriate amendment to the Act,

The Government must work through the Ministry of Finance and in collaboration with the Office of Special Prosecutor to streamline the suspense regime at the port. The current customs management system must be thoughrouhly reviewed to plug all lope holes to maximise revenue generation at the ports.

These are some of the government’s agenda to artificially create cosmetic fiscal deficits whilst saddling the people of Ghana with hidden debts and collapsed institutions. The truth is, “you can do all the propaganda about the fiscal deficit, but the public debt and collapsing state agencies under heap of unsustainable debts will expose you”.
Revenue and Expenditure Performance

The commitment to improve our revenue and expenditure performance have not been given the attention it deserves. In order to anchor the finances of a country on sound footing, two key this have to happen;

A Government must aggressively pursue progressive tax policies that take more proportionately more from the rich whilst ensuring that a reasonable proportion of national income is available to Government to pursue programs that improve livelihood, better service delivery and an enabling environment for the domestic private sector to take the commanding heights of value and wealth creation for prosperity for all.

Secondly, Government spending from the revenues so collected is efficient, effective and delivers value for money through appropriate systems of control, monitoring, reporting, assurance and sanctions regime for violations.

With the foregoing in mind, I will now pay my attention to Government’s fiscal management from 2013 to 2016, 2017 to 2021 and the projected medium-term outlook from 2022 to 2024.

Mr Chairman, Figure 2 and Figure 3 below depict Ghana’s revenue performance in the last four years. Please note that all revenue classifications are expressed as a percent of GDP. The average of each revenue type for the period (2013 – 2016) is compared with the average for the period (2017 – 2020). Simply put, revenue performance under four years of the then NDC government headed by H.E John Dramani Mahama and four years under the first term of the current NPP government of H.E Nana Addo Danquah Akufo Addo able supported the renowned economist and head of the economic management team, H.E Dr Alhaji Mahmoud Bawumia. From the Figure 2 below, revenue performance on average for the period (2013 – 2016) is higher than it was for the period (2017 – 2020).

Figure 2: Average Performance in Revenue (% of GDP)

I am sure Ghanaians still recall the famous slogan “we will shift the focus of economic management from taxation to production”. Tax revenue (non-oil) measures the real sector contribution to tax revenue. It depends solely on the productivity of the real (non-oil) sector of the Ghanaian economy.
It is important to note that a fiscal policy measure aimed at moving the economy from taxation to production would mean that the non-oil real sector of the economy such as the spare parts dealers at Abbossay Okai, Kokompe and Suame, market traders such as those at Makola, Mallam Atta Market, Kejetia and Ayia in Bolga would see astronomical growth in their sales volumes and profitability as they plough back the tax cancellations and or reductions to expand their businesses. Government will now be able to rake in more revenue by taxing this expanded growth in national income and disposable income. This was the simplistic view of the Ghanaian economy and value chain that was championed by Dr Bawumia from his eloquent lectures to becoming NPP manifesto and a still born Government Policy.

What has been the response of the sector in terms of its contribution to tax revenue since the superfluous and ill-conceived simplistic understanding of Ghana’s economy leading to the elimination of the so-called nuisance taxes in 2017. The shift towards elimination of taxes should have indeed translated into increased productivity that will sustain the growth in tax revenue. On the contrary, the year-on-year growth in non-oil tax revenue started declining after 2017.

You will recall that in 2017, during the budget debate in Parliament I warned the Minister for Finance, Hon Ken Ofori Atta and Dr Bawumia that they could not use ‘ceteris parabus’ principles to manage the Ghanaian economy with complex institutional and structural rigidities. That the simplistic view that the lower the taxes, the higher the out of the private sector and the higher the non-oil tax revenue strangely ignored the complexities of challenges confronting the formal and non-formal private sector that needed to be addressed to unleash the desired growth.
What is worrying is that the fiscal path in the medium-term from the above shows that Government expect a 580% improvement in non-oil tax revenue improvement but that it will deteriorate below its worse performance during the pre-covid period when the economy should be improving.

The whole rhetoric on the shift from taxation to production was mere propaganda. Paragraph 19 of the 2017 Budget read “Mr. Speaker, the Budget will set the pace for job creation and accelerated growth by empowering the private sector. To accomplish this, we will shift the focus of economic management from taxation to production. This will reduce the cost of doing business and create a conducive climate for investment and job creation. In this regard, a number of taxes that impede growth will be reviewed, and if necessary, abolished. Government will reverse the recent low growth trend by boosting agriculture and industrial productivity. The NPP government at the time was determined to eliminate a number of taxes that were considered nuisance taxes and inimical to private sector growth.

There are also some worrying developments in the expenditure front. Debt service alone takes about 91%cpercent of our tax revenue. Only 9% of tax revenue is available for other critical spending. The implications of government’s increased appetite for borrowing started manifesting in 2019 when debt service (interest and amortization) as a percent of tax revenue exceeded 70 percent. This trajectory will be maintained even in the medium term and will reach 91.6 percent in 2021. Figure 4 below provides clearly the picture of Ghana’s debt service.
Overall Fiscal Deficit Dynamics

It has been an era of cosmetic fiscal deficit reporting since 2017. As previously stated, a number of alien schemes are explored by government to artificially suppress the fiscal deficit. This purpose has however not achieved because the IMF has keenly followed development within Ghana’s public finances. Figure 5 below compares fiscal deficits reported by government with the IMF. After 2017, Ghana’s fiscal deficit as reported by the IMF was on the rise, reaching 7.3% of GDP by 2019, an indication that our public finances were worsening. Government ignored these signals and consistently reported cosmetic fiscal deficits which was not a true reflection of the state of public financing in Ghana. Ghana’s public finance management stated deteriorating even before covid-19.

Figure 5: Trend in Fiscal Deficit (% of GDP) – IMF vrs GoG

Source: IMF WEO (https://www.imf.org/en/Publications/WEO/weo-database/2021/April/weo-), MoF (https://www.mofep.gov.gh/index.php/fiscal-data)

Public Debt, Sustainability and External Vulnerabilities
There has been major concerns about Ghana’s public debt dynamics since Dr Mahmoud Bawumia became the head of the economic management team of Ghana. In measuring and evaluating public debt and its sustainability, the focus has to be on either the quantum or size of the public debt as well as its quality in relation to its inherent risks to the fiscal health of the country, growth of the economy and its impact on Ghana’s external vulnerability.
The quantum of the public debt pose serious questions regarding the efficiency of utilisation in pursuit of critical national development needs and how it has impacted the size of the economy.

Thus, when Ghana’s public debt grows from about GHC120 billion to about Ghc400 billion in just five and half years years, legitimate enquiries must be made into what the monies were used for when we have very deplorable roads, kids in SHS are running double track systems, new hospitals have not been built and the old ones ill equipped to deliver fit for purpose health care etc.

The second question to be addressed is how the huge public debt is expanding the size of the economy and creating a pool of national income for increased revenue mobilisation of tax and non-tax revenue to service the public debt, amortise it when due and still leave a reasonable fiscal space to fund critical national development. Government’s borrowing program must be aligned to growing the economy and funding growth enhancing expenditures such as infrastructure to give the country and its citizenry a chance at enhanced livelihood and economic well-being through jobs, improve social service delivery and enabled private sector. This is often measured by measuring the present value of public debt as a percentage of the size of the economy called the GDP

Ghana’s debt to GDP shows that whilst our public debt is growing at a faster rate, the economy is not growing at a level that is required to anchor debt sustainability. In order words, we are not growing the income earning opportunities of Ghanaians, so Ghana is not generating the pool of income necessary to ensure that we can generate significant resources from the economy to pay for and service these debts.

Debt to GDP improved slightly in 2017 from 56% in 2016 to 55% in 2017 consistent with the improvement in the economy from the seeds sowed by H.E John Dramani Mahama. From 2018, the debt to GDP began to worsen to 57% above the 2016 levels and increased further to 67% in 2019. Clearly, Ghana’s economy and trajectory had long gotten worse by 2019 and could only get worse in 2020. The end year 2020 debt to GDP crossed the dreaded 70% to 72%.

What is worrying is that Government and the IMF projections show that it is getting scary as Ghana’s debt to GDP’s medium–term path shows a period end figure of 86% by the end of 2024.

Another important measure of the quality of Ghana’s public debt is our ability to service both the interest and principal payments when they fall due. A key measure of this risk of default is the proportion of our tax revenue we use to pay for debt service. Do we have enough room or fiscal space based on the public debt service, size of the economy in relation to tax, non-tax and other domestic revenue mobilisation?

Ghana which used to spend about 66% of its tax revenue to service its debt, spent about 72% of its tax revenue in 2019 to service its debts, leaving only 28% of tax revenue to fund critical infrastructure. This was not induced by Covid.

By the end of 2021, Ghana used 129% of its total revenue to pay for debt service, leaving only 9% for other critical infrastructure. In the medium term, Ghana’s debt service to GDP is expected to increase from 66% in 2016 to about 78% in 2024. Ghana’s economy is in dire straits and need more than an intensive care unit to revive it.
Based on the rate of increase in debt, the World Bank and the IMF joint DSA analyses under the Joint Bank-Fund Debt Sustainability Framework for Low Income Countries for 2019 and published in April 2020 showed that Ghana’s risk of external debt distress and the risk of overall debt distress was high (https://www.worldbank.org/en/programs/debt-toolkit/dsa).

According to the report, the high risk of debt distress was due to higher projected deficits and debt service. The findings further showed that external debt service continues to absorb a third of government revenues and remains well above thresholds for most of the forecast period. The present values of external and public debt-to-GDP ratios exceed their thresholds. This was Ghana’s debt situation back in 2019 when we didn’t have anything called Covid-19.

In managing public debt, it is important to build adequate buffers to prepare for headwinds when they occur. A country is faced with the possibility of several external and internal shocks that may dislocate fiscal and external stability. To deal with this, a country must be adequately prepared to weather the storm.

These factors must be analysed to determine the quality of a country’s public debt. Any time Ghana borrows foreign currency denominated loans, we expand the country’s obligations in foreign currency and must build buffers of foreign reserves to pay for interest and the principal when they fall due or when non-resident holders of those bonds decide to sell off and exit the market with their monies. Of course these investors are paid either in foreign currency or in cedis, but they must return to their countries with foreign currency and not the cedi.

It is for this reason that a country like Ghana that has about 50% foreign currency denominated debts and a further 30% of its domestic cedi denominated bonds held by non-residents who brought foreign currencies to the country, sold the foreign currencies to their banks for cedi and bought our cedi bonds need a lot of foreign currency buffers. More loans in foreign currency is akin to drinking more poison as your foreign currency obligations soar, leading to heightened external vulnerability and exchange rate pressures.

There are several measures of a country’s vulnerability resulting from increased holding of foreign denominated currency debts. These measures aim at identifying the capacity of the country to either generate foreign currency or the levels of foreign currency buffers to ensure adequate forex liquidity.

The relationship between Ghana’s public debt and its export earnings gives an indication of the foreign currency earning potential for the accumulation of forex buffers. Unfortunately the outcome of the last two joint IMF and World Bank Debt sustainability analysis of Ghana shows that Ghana has breached the threshold of this measure for debt sustainability signifying heightened external vulnerability.

Another measure of external vulnerability is the adequacy of net reserves of foreign currency with the BOG to cover for short-term non-resident capital holding in the country. As a rule of tumb, a country must have at least $2 for every dollar of short-term capital holding of non-resident investors. Over the last couple of years, declining net international reserves of Ghana has resulted in breaches of this prudential foreign currency reserve requirement. By the end of 2019, Ghana’s net international reserves could hardly cover for 50 cents of every $3 short-term capital holding of non-resident investors.

You will recall, the significant reversal of portfolios of domestic bonds held by non-residents in Ghana and mounting uncovered-auctions led to excessive depreciation of the cedi as our buffers were inadequate to stem the huge liquidity demands in the market.

High debt service even if it were covered by good tax revenue generation will still require high levels of foreign currency reserve buffers to be able to pay the foreign currency obligations imposed by the high component of foreign currency debt service. This is the reason Ghana’s external vulnerability has been heightened by high foreign component of public debt, low levels of net reserve buffers and high demand for increased export earnings. This has resulted in a cycle of more foreign currency denominated bonds to provide artificial buffers, further worsening debt service obligation and more poison to the economy.

Failed Monetary Policy and Financial Stability

The Bank of Ghana has the mandate to manage price developments to achieve stability and exercise responsibility for a sound and stable financial sector.
In the last couple of years, the BoG has failed woefully to anchor price developments.
By 2019, Ghana inflationary trajectory had moved into double digits with BoG failing to deploy monetary policy to stem it. This was also the case with the depreciation of the cedi and interest rates. The central has been more of a political anchor of Government and less of an autonomous technocratic monetary policy and external anchor. After the fiscal expansion in 2020 and 2021, the BoG should have taken steps to mob up excess liquidity it failed and continued to stick a political nice low policy rate that was hurting the inflation targeting frame and managing inflation expectations.

In 2021, global projections and positions taken by analysts in the capital markets showed that there was imminent hikes in interest rates in developed countries, signalling an imminent return of investments to USA assets but the BoG was dead inactive, By September 2021, offshore investors had intensified sell off of their portfolios in emerging countries , including Ghana but the BoG did nothing to encourage them to lock in their funds in Ghana.

As non resident investors intensified reversals of the bond holding, the central was busy throwing its limited foreign currency at them whilst still keeping its biggest weapon, the policy rate sleeping. At this point, Government was struggling to raise money on the domestic market with the central busy creating more money and throwing at Government instead of respond with appropriate monetary policy stance with Dr Bawumia still shouting at the UCC that policy rate, we have done better.

Ladies and Gentlemen, by the time the BoG woke up from its slumber and started tinkering with its policy rate, offshore investors had left the market with our reserves, the international capital market had shut the door on Ghana, the cedi was feeling the pain of the liquidity flight and monetary policy had become inconsequential resolving inflationary pressures, interest rates and depreciation of the cedi.

The end result is that the dysfunctional monetary policy which has lost credibility was beginning to watch on us Government bear the consequences of colluding with the BoG to raid the safe of BoG to illegal collect 22 billion and still counting. As BoG is trying so hard to recall the cheap monies it illegal gave Government though raising policy rates, the Government is now paying for the costs raiding BoG to break into its safe to take Gh22 billion high record interest rates and now wondering it is going pay for it in a budget already working just for debt service,
As the saying goes, there is no free lunch but this time the unsuspecting private sector and household are now suffering because they can’t borrow to run their businesses or live their lives and where they find the money to borrow, they end working for the lender.

Ghana’s capital market has now collapse with excessive yields, sometimes as high as 40% with huge offers without bids across the yield curve,

As investors have shun Ghana bonds and demanding outraging yields on our domestic and Eurobonds, rating agencies belatedly had to respect investment sentiments and are now all in tandem with their rating Ghana at a junk and defaulting nation.

Collapse of Financial Sector of Ghana.
Ghana’s financial sector has come under enormous predatory attacks by hawks in the financial sector who have assumed the reigns of financial governance and regulatory dominance in the country.

For so many years, people who struggled to compete in the financial sector and had tried to acquire certain banks and failed suddenly were entrusted with the responsibility to manage Ghana’s finances and granted the licence to influence the design of Ghana’s financial sector regulatory architecture.

In 2017, when Ken Ofori Atta was appointed the Finance Minister and senior members of his company, Databank Ghana Limited began to be appointed to key regulatory institutions in the very sector where he had struggled for years to dominate such as the BOG and Securities and Exchange Commission, I raised an alarm that fell on death ears.
Ladies and Gentlemen, I raised an alarm on various platforms at the time that by the time Ken Ofori Atta is allowed to infiltrate the financial sector regulatory agencies with senior members of Databank and with him as the finance minister, he will become the biggest risk to Ghana’s financial sector.

As he began to weave his and Databank dominance in the regulatory space, shivers run down my spine. I knew the financial sector was on the verge of an enormous regulatory attack that will change the face of the financial sector for worse and bring down illustrious Ghanaian entrepreneurs in the financial sector, leaving Databank and its subsidiaries and affiliates to feast on the spoils.

The Master tactician, Ken Ofori Atta sat back at Ministry of Finance with the public purse in his hands to waste public funds in an unimaginable fashion to get this through. A founder and Vice President of Databank and his long-time ally, Kelli Gadzekpo was appointed to the Board of Directors of the foremost banking sector regulator, BOG. Then followed by Rev Ogbamey Tetteh, also a Vice President of Databank was appointed to the Governing Board of the Securities and Exchange Commission and as the Director General of this foremost regulator.

With Databank now in control of the Ministry of Finance and SEC as well as pipping in the Board Room of BOG, the stage was now set to unleash terror and greed on Ghana’s financial sector.

In 2017, the first leg of the predatory instincts of this lethal force was set in motion. The BOG announced what seemed harmless but laden with slow poison to wipe out the financial sector in general and competitors of Databank and Enterprise Group and known opponents of NPP.

The BOG revised the already announced minimum capital requirement of GHS230 million for banks to GHS400 million and requested banks to comply with the new requirement in one and half years instead of the three years.
Ladies and Gentlemen, as the banks were contemplating how to deal with this challenge, they appealed to the Minister for Finance to pay arrears totalling over GHS5.7 billion owed to contractors they financed by Government. They indicated that the payment of the contractors will enable the contractors to pay back their loans owed to the local banks to contribute to them meeting the new minimum capital requirement.

Ken Ofori Atta now had the local banks exactly where he wanted them; refuse to pay the contractors so that they are forced by the BOG to write the GHS5.7 billion off their capital, thereby weakening and pushing them to insolvency to be pounced on by the BOG.

At the time, a number of banks openly complained that Ken Ofori Atta’s refusal to pay them was collapsing their banks but this rather emboldened Ken Ofori Atta to tighten the screws on them to collapse them

As Ken Ofori Atta continued to squeeze them, the BOG intentionally and as part of the scheme created fear upon fears in depositors by inciting those against the local banks with claims that suggested the local banks could not meet the minimum capital requirement more than a year before the deadline.

This fear got worse in August 2017, BOG in a Rambo-style take over closed down and revoked the licences of UT Bank and Capital Bank and set a PR machine in motion to discredit the shareholders and directors of these banks to divert attention from Ghanaians uncovering the true intent of their game plan and their celebration of the collapse of their first casualty.

As the inquest raged and Ghanaians began to panic withdraw their monies from local banks, the bank of Ghana as usual announced half-hearted deceptive ploy on Ghanaians. They claimed that the banks had not been collapsed but had been assumed by GCB Bank and the staff of the affected banks employed by GCB Bank.
This was a grand deception. Because a receiver had been appointed to sell off selected assets of the banks, recover outstanding loans and pay off liabilities thereof. In other words, once the licence of these banks were seized and a receiver was appointed for them, they ceased to be a going concern and were technically being prepared for burial by the corona.
To date, no one has sighted the so called purchase and assumption agreement which formed the basis for the huge pay out of GHS2.2 billion to GCB Bank.

The tragedy is that UT Bank was engaging investors willing to provide the recapitalisation but had requested the BoG to agree to restructure its liquidity support Ghc800 million to UT Bank for a period of 3 years as a precondition for their investment in UT Bank that would have saved UT Banks and over 2000 Ghanaian jobs and livelihood.

The BoG refused, revoked the licence of UT Bank, wrote off the Ghc800milliom in UT Bank it refused to restructure to save the UT Bank and spend a further Ghc1.2 billion to collapse it. In all, the BoG got Ken Ofori Atta to obtain approval from Government to spend Ghc2 billion to collapse UT Bank could have been saved at no cost to the state except a restructuring liquidity support for 3 years.

The first casualty from Kukurantumi was gone, workers lost their jobs and livelihoods and the banking received a rude awakening to the magnitude of the predatory architecture at work.

All this while, local banks were getting weaker and insolvent everyday as depositors cued to withdraw their monies. For every day that depositors withdrew their monies from the banks, they created deeper holes in their accounts and increasing the amount of monies the banks needed to cough up to meet their minimum requirements and also remain solvent.
The financial sector had just began showing all the symptoms Databank and Enterprise Group senior members sent to regulatory agencies were waiting to see. Insolvencies and unattractiveness of the local banks to investors. They were now available for BOG to take as many down as possible. As the local banks bled to death, Ken Ofori Atta refused to pay the Ghc5.7 billion arrears owed to clients of these banks to save them from collapse.

As all these were going on in the banking sector, Rev Ogbamey Tetteh and his SEC were also preparing a dose of poison to wipe off SEC regulated businesses. To do this, they first needed to ensure that Databank was completely insulated from the bomb they were about to throw at the industry.

They threw the bomb in May 2018 but before throwing the bomb, Databank and its affiliates went about redeeming their investments in all the financial institutions regulated by SEC before they were administered the poison by SEC. This was the same thing that happened before UT/Capital Bank were taken down.

Then after Databank and Enterprise Group have moved their monies, Rev Ogbamey Tetteh issued a directive to the effect that all fund management companies should go and bring all depositors monies they had invested within six months. This was the beginning of the collapse of the SEC regulated industry in Ghana.

Since these companies invested among themselves and with our local banks, a major panic withdrawal ensued, this time among institutional investors. Financial institutions that were generating and investing millions of excess cash every month, began to experience millions of net withdrawals a month. This was not sustainable as no deposits were coming in only withdrawals. Our local banks were now experiencing panic withdrawals of wild-fire proportions and were simply resigned to their fate

Interestingly, in all this melee, only Databank and Enterprise Group were not affected because they had already taken all their monies from the system before the poison was administered by their hatched man at SEC, Rev Ogbamey Tetteh.
As the SEC regulated companies and the local banks were suffocating and panting for breath, BOG stoked more fire. They announced that more financial institutions totalling 272 were going to be taken down without mentioning them. Immediately, all financial institutions became candidates for the impending action by BOG leading to further intensified panic withdrawal.

Ladies and Gentlemen, as the banks and financial institutions were beginning to recover from this panic withdrawals caused by regulatory-induced systemic fear, the Bank of Ghana added another fierce nail to the coffin. The licences of 5 more banks were withdrawn under dubious situations.
Strangely, two of those banks were given final operating licences and out-doored with pump and pageantry by the Nana Addo Government. The Beige Bank was licenced by BOG in 2017 and launched by no mean a person than Dr Addison, the Governor of the BOG.

The Bank for construction was one of the banks whose licence was revoked. This bank was licenced in 2017 and launched by Dr Bawumia himself as a Vice President. When Dr Bawumia says the banks were suffering from a cancer of the toe that needed to be cut to save it from spreading to the body, we now see when the banks were infested with the cancer. Dr Bawumia and the NPP Government when they assumed office set in motion to infest the banks with this cancer of predatory regulatory attack, systemic fear and the resultant intense bushfire- like panic withdrawal that engulfed the entire financial sector as they had strategically planned to consume 9 local banks of competitors, 347 savings and loans and micro-finance institutions as well as over 50 SEC regulated companies.

In December 2018 at the deadline of the recapitalisation program, Heritage Bank, a very solvent bank with strong risk management systems and certification was collapsed under spurious politically motivated circumstances.
Ladies and Gentlemen, it is worthy of note that Capital Bank was targeted by Databank for acquisition by Ken Ofori Atta and Kelli Gadzekpo for Databank without success. A couple of months after Ken Ofori Atta becoming Finance Minister and Kelli Gadzekpo becoming a member of the Board of Directors of BoG, BOG collapsed Capital Bank and Ken Ofori Atta raised GHS2.2 billion to pay for its burial.

Ken Ofori Atta and Babatunde Ampah, a Vice President of Databank in charge of corporate finance approached the owners of Beige Bank to acquire it. The owner refused and a few months later, Babatunde Ampah led staff of the BOG to take over Beige Bank even though he is not a staff of BOG. Subsequently, Babatunde Ampah was appointed a member of the board of Directors of CBG which took over Beige Bank and put in charge of Beige Bank.

Ladies and Gentlemen, a couple of weeks before revoking the licence of Heritage Bank, BOG asked the owner of Heritage Bank to merge with UMB but he declined after due diligence by KPMG on UMB revealed issues with the quality of its related party transactions on its books. A week later BOG revoked the licence of Heritage Bank.

A couple of months after revoking the licence of Heritage Bank and adding it to consolidated bank, the Governor of the BOG, Dr Addison sent foreign investors who were interested in acquiring Heritage Bank to go and negotiate with the majority shareholder of the bank to buy it from him.

Obviously, after taking his bank, Dr Addison now set a trap for the owner of the bank so he can accuse him of fraudulently selling Heritage Bank when he knew that the bank had been confiscated to the state. How wicked can you get?

Ladies and Gentlemen, it is sad to note that when the BOG revoked the licences of these banks, BOG refused to pay deposits and investments of financial institutions such as savings and loans companies, finance houses, fund management companies, rural community banks and micro finance companies to them to enable them pay their customers and restore confidence in their operations.

Instead, they denied them their funds leading to further panic withdrawals from their customers until they could no longer meet the demands of their customers. Instead of releasing their monies to them, BOG and SEC rather revoked their licences.

The story of some of the collapsed banks were so pathetic it is difficult to believe that a colleague in the same industry did that to them. Unibank was owed in excess of GHS1.2 billion by Government and was written to by KPMG to save it but Ken Ofori Atta refused to pay.

The case of GN Bank and Gold Coast Securities is heart-breaking. Ken Ofori Atta refused to pay contractor obligations totalling over GHS2 billion that would have saved the bank and its Gold Coast Securities.

In the 1980s through the ‘90s into the 21st Century, the Bank of Ghana (BoG) and its sister regulators maintained their status as bodies of integrity, where confidence and transparency were their sworn words in the execution of their duties. The management of these state agencies were tactful and decent such that they respected all tenets of their profession to the letter. These earned the leaders and the institutions aura and clout and that helped in their regulatory works.

Sadly, however, this is no longer the case. Since 2017, Ghana’s financial sector has been suffering from a tragedy of incompetence, rowdy regulatory antics, a ‘try and error’ leadership and a deliberate attempt to create confusion in other for a select few to profit, amass wealth and satisfy their innate desires of being the wealthiest and most influential persons and families in their party, Ghana and Africa at large.
Transforming the economy: the hard choices

It has been established that Ghana’s economy has been badly exposed by its heightened fiscal risks, struggling financial sector, external vulnerability, debt crisis and monumental monetary policy failure. To transform Ghana’s economy, we need to make hard choices to provide enduring short-term resuscitation and stability and forge a medium to long term sustainability and outlook as a key impetus to a transformation of the economy.

The focus should be to resolve the current economic challenges as soon as possible and introduce reforms that will anchor stability and change the fundamental structure of the economy. These choices should to and efficient monetary policy dynamics to anchor price developments such as inflation, interest rates and cedi depreciation.
The fiscal environment should be reformed to anchor debt sustainability, compliment monetary policy and promote financial stability. The key interplay of fiscal sustainability, efficient monetary policy and financial stability should balance capital market efficiency and external sustainability.
In the long term, deliberate policy choices have to be made to place emphasis on modernised and technologically driven large scale agriculture and integration to agri-business to drive industrialisation, enhance service delivery to support agriculture, industrialisation and deliberate Ghanaian value driving natural resource governance architecture.
To achieve this, the fiscal, monetary policy, financial and capital market activities must be engineered to support agriculture, industry, services and deliver modern infrastructure while protecting social spending and social protection.
Unfortunately, our planning and development framework has become extremely fragmented, medium term and partisan as we have tended to Govern by party manifestos and not by a long term national vision and plan. We need to go back to a national discourse on a national development plan that would inform medium term and annual budgets and policy choices.
My proposals for transforming the economy of Ghana will be based on four (4) pillars of reforms. These include;
Reforming planning framework for national development.
Fiscal reforms to support fiscal and debt sustainability.
Investment reforms to accelerate infrastructural development, ease budgetary pressures and focusing and equipping funding and regulatory investments on industry, natural resources and strategic service sectors to reform the structure of the economy
Monetary policy and financial sector reforms to ensure effectiveness, efficiency, transparency and credibility.
Ghana must development an enduring national development plan to inform medium to short-term development plans. It is strange that we can borrow for a tenure of 40 years and even contemplated a century bonds until the capital markets saved us.
There must be a deliberate legal framework annual monitory and performance reports on medium terms plans during its implementation and its completion to inform learning and reforms going into the next cycle of planning.
The annual budgeting framework should be reviewed. The public financial management Act should be reviewed to improve transparency and stakeholder inputting. It should be mandatory for Government’s approved fiscal strategy document and fiscal risk statements together with Government economy policy and sectorial programmes to be presented to Parliament for reviews, debate and a comprehensive Parliamentary feedback to the executive to inform resource allocation. This will ensure that Parliaments deliberations are factored into a revised economic policy document that reflect the dreams and expirations of Ghanaians and consistent with our cherished national vision. Currently, Parliament’s work are at best a display of knowledge and a talk shop.

The budget estimates and allocations to ministries, departments and agency should be presented to Parliament separately and subsequently but accompanied with the final economic policy document approved by Parliament to provide guidance in approving the budget estimates and allocations.

Parliament must set up a scrutiny office with capacity to provide technical back stopping to committee and members in analysing and informing inputs on various sectors and policies to improve the quality of Parliament’s work on economic policy and national budgets
In the short term, the following expenditures should be scrapped to save about Ghc5 billion in 2022 budget and scale down the budget and primary balance deficit.
. Ghc 1 billion from other Government obligations centralised at the ministry of finance for a mystery Ghana Cares Obatanpa.
. Ghc 1 billion from other Government Obligations for YouStart centralised at the ministry of finance.
. Ghc 1 billion from other Government Obligations for Ghana Amalgamated trust for state capture centralised at the Ministry of Finance.
. Ghc1.3 billion earmarked for development authorities and transfer their ongoing projects to the district, municipal and metropolitan assemblies in which these projects are allocation.
. Expenditures totalling about Ghc3.6 billion centralised from the proceeds of the obnoxious capping and re-alignment. This should help provide resources for alignment to fund essential services.
. The cumulative effect of these cuts will save the country about Ghc6.9 billion of tax payers money and reduce the 2022 budget deficit and public debt.
. Government should review the budget and cut a total of about Ghc10 billion from 2022 budget by finding additional cuts from its earlier announcements to cut 30% of the budget. This will require a cut of just Ghc3.1 billion in addition to the specific cuts of Ghc6.9 billion identified above.
1). Abolish or amend the capping and realignment Act to exempt Getfund, NHIA, GIIF and Exim Bank. This should release between Ghc900m to Ghc1 billion) annually to scale up funding educational and health infrastructure. The additional revenue from reforms to the capping regime to refinance education and health care should be ring-fenced through the establishment of a holding account at the BoG for each stream of revenue to dedicated to specific projects in education and health implemented by Getfund and GES in the case of education and NHIA and GHS in the case of health.
2) Review the E-Levy and remove it as a consumption tax on the poor and vulnerable leading to a drastic reduction in momo and electronic transaction which is hurting and threatening to roll back fin-tech growth and development in Ghana. The levy should be imposed as a final tax on the fees earned by Momo and E-money companies. This should help restore and growth volumes, generate profitable volumes for Fin-Tech companies, grow the industry and make more money available to Government.
3). Government should abolish the bench mark system of custom valuations at the port and encourage compliance with the customs Act which encourages the use of transaction values for customs valuations.
4) Re-introduce automated Pre-Arrival Assessment regime that allows all importers to upload and submit all their shipment documentation to customs for PAARs to fast track customs classification, valuation and application of the various risks management tools provided for in the Customs Act to validate and ensure the payment of appropriate duty, taxes and levies to Government. This should eliminate the self-serving and abusive use of advance ruling procedures to deny the state of badly needed revenue.
5). Tighten the suspense regime at the port to stop the bleeding at the ports through dubious suspense procedures.
6). Undertake an independent review of the efficiency, effectiveness and adequacy of the new customs management system used at the port (ICUMS) and institute immediate systems improvement to augment revenue generation.

Reforms to Anchor Debt Sustainability
Review and propose amendments to Parliament to re-align the Petroleum revenue management Act to urgent need to build the sinking fund for debt sustainability and inject confidence in the capital market.

The reform to the PRMA should aim to maintain the current arrangement for the heritage fund and abolish the ABFA and Stabilisation fund into a unified arrangement to fund the sinking fund sole for debt amortisation of Eurobonds. This has the potentially to generate between $800 million to $ 1 billion to fund Eurobond maturities.

The building of the sinking fund will help reduce the interest payments and the impact of exchange losses on the national budget and help restore fiscal and debt sustainability and soften investor sentiments.

The Public Financial Management Act must be reviewed and proposals for amendment made to strengthen debt management and make the utilisation of the sinking fund a bi-annual reporting requirements with clearly defined framework. This should include a forecast of all expected flows to the fund, actual receipts, forecast maturities to be amortised for each debt and actual amortised. The auditor general must audit the sinking fund and provide a separate compliance annually to Parliament to validate the semi-reports submitted.

. Reform Investment Promotion, PPP, Funding and Alignment to National Transformational Priorities.
.Consolidate Ministries to create room for the establishment of a ministry for Investment Promotion, PPP and Infrastructure Development.

This will help provide policy direction and leadership to focus investment promotion, PPP and funding of priority investment in infrastructure, industry, agriculture and strategic growth enhancing service sectors.

Reform Ghana investment promotion centre and Free Zone Board into Authorities and bring them under the ministry for investment, PPP and Infrastructure.
.Reform and refocus Ghana Infrastructure Fund as Government’s funding vehicle for infrastructure, extractive industry, strategic services and implementation of PPP arrangements and put it under this ministry,
Refocus Exim Bank as a strategic funding vehicle for investments in modernised agriculture, irrigation development and export-oriented industrialisation.
Identify investors, design and create PPPs for major infrastructure projects and take them of the national budget and utilise the balance sheet of GIIF to leverage funding to deliver those projects.
For instance, GIIF could partner the private sector provide first class dualised (several lanes) Accra-Kumasi road, Accra Takoradi Road, Accra-Aflao, Accra-Ho, Kumasi-Cape Coast, Kumasi-Paga, Kumasi-Sunyani roads) on PPP and ease the national budget of these costs and focus the national budget on social spending such as education, health care and security etc.
The free zones authority, Ghana Invest Promotion Authority and the Exim Bank can work together to promote transformation of industrial growth and industrialisation whilst ensuring Ghanaian content.
The reforms to the PRMA should also secure funding for GIIF and Exim Bank in the next few years until we achieve debt sustainability. When we finally bring our debt to a sustainable situation, a greater part of the funding to the sinking fund should made available to GIIF and Exim Bank to scale up infrastructural transformation and a sustainable shift in the fundamental structure of the economy.
The ministry must sponsor a legislation to harmonise all investment laws and fiscal rules to develop an investment code to support provide a congenial and attractive environment to attract investment.
Monetary Policy, Financial Sector and Capital Market Reforms.

It has been a big challenge to promote an effective, efficient and transparent monetary policy to manage price developments such as inflation, interest rates, cedi depreciation and at the same time ensure a sound and stable financial system that allows for an efficient, credible, transparent capital market.
Far reaching reforms are required to restore confidence, anchor monetary policy and promote a sound and stable financial sector and efficient capital market.
I propose a splitting of the Bank of Ghana into two autonomous bodies;

1). A financial conduct authority for managing and promote a sound, ethical and strong financial sector…
BoG with sole responsibility for Monetary Policy and External Vulnerable. This should help produce an effective, efficient BoG not distracted by responsibility for financial stability to work to get a handle on stable inflation, interest rates and manage the stability of the revered currency, the cedi.

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