Africa Policy Lens Files RTI Request Over Bank of Ghana’s Gold Divestment

Policy Think Tank Africa Policy Lens (APL) has formally requested detailed disclosures from the Bank of Ghana (BoG) regarding the divestment of a portion of the nation’s gold reserves in the last quarter of 2025.

In a letter addressed to the Governor of the Central Bank and submitted under the Right to Information Act, 2019 (Act 989), Dr. Hayford Mensah Ayerakwa, Director of Research, Administration, and Partnerships at APL, seeks clarity on what the organisation describes as a matter of “significant national interest,” given gold’s central role in Ghana’s monetary stability and external reserves management.

Dr. Ayerakwa argues that, in a period marked by rising global gold prices and heightened central‑bank accumulation worldwide, any large‑scale divestment demands full public transparency. The letter calls on the Bank to provide a comprehensive breakdown of the transactions executed during the period in question.

APL is requesting the Bank of Ghana to release 20 categories of information, including:

1. Confirmation of the total quantity of gold divested, including the precise weight in tonnes and ounces in quarters 3 and 4 of 2025.
2. The exact dates on which each divestment transaction was executed.
3. The London Bullion Marketing Association (LBMA) reference price or pricing benchmark applied in valuing the divested gold.
4. The average realised sale price per ounce for the gold sold.
5. Full disclosure of the identities of counterparties or purchasing entities involved in the transactions, including beneficial ownership, and how the owners of all the companies involved in the sale of the gold are structured.
6. Clarification on whether there were any local partners involved in the sale of the gold, and if so, the identities and ownership structures of such local partners.
7. A description of the transaction structure, indicating whether the gold was sold outright, swapped, leased, transferred under any structured financial arrangement, or subject to any buy-back clause in the divestment transaction.
8. Details of the mode of transfer or delivery, including the custodial chain, and information on whether the divested gold has been shipped out of the country and, if so, the dates of shipment.
9. The total proceeds realised, specifying the currencies in which the proceeds were received.
10. Information on the accounts or financial instruments into which the proceeds were credited, including information on how these funds were applied, whether toward reserve management, debt servicing, investment activities, or related purposes.
11. Disclosure of any financial advisors, consultants, bullion banks, brokers, or transaction advisors engaged in facilitating the transactions, including the identities of such advisors.
12. Information on the commissions, fees, or other compensation paid in relation to the transactions, including how much commission was paid, to whom such commissions were paid, and how much the transaction advisors received.
13. The policy rationale or strategic justification for undertaking the divestment at the particular time, including the economic reasoning behind the sale of the gold.
14. Clarification on the market indicators, analyses, or projections that informed the decision to sell the gold, including whether the Bank of Ghana conducted strategic market timing analyses prior to executing the divestment, particularly in light of projections indicating rising gold prices toward $5,000 per ounce.
15. Confirmation of the decision-making authority responsible for the divestment, including who made the decision to sell the gold.
16. Confirmation of Board approval, including the specific date on which the Board sanctioned the divestment.
17. Clarification on whether the decision was a Cabinet decision, and whether the Ministry of Finance was involved in or informed of the Central Bank’s decision and processes.
18. Clarification on whether Parliament was notified of the decision to divest part of the national gold reserves.
19. Clarification on the rationale for the subsequent decision to rapidly rebuild gold reserves following the divestment exercise.
20. Clarification on issues of accountability, including who will be held accountable for possible losses to the country within the period of the divestment.

Call for Transparency and Timely Response

APL emphasises that the disclosure is required not only for public accountability but also to clarify inconsistencies in public discourse surrounding the management of the country’s gold reserves. Dr. Ayerakwa notes that the organisation expects a response within the statutory timelines set under Act 989.

“The people of Ghana deserve full clarity on the strategic decisions involving our national gold reserves,” the letter states, adding that such transparency is vital for ensuring trust in the stewardship of the nation’s financial assets. The Bank of Ghana has not yet issued a public response to the request.