Advisory Procedure for Foreign Gold Off-Takers

Navigating the 2025 Ghana GoldBod Act Licensing Framework

1. Executive Summary

Sterling Shadow SL Ltd provides strategic advisory and facilitation services for foreign entities seeking to legally purchase and export gold from Ghana under the Ghana GoldBod Act, 2025 (Act 1140).

As an advisory and facilitation partner, Sterling Shadow SL Ltd supports clients throughout the licensing, compliance, and operational lifecycle required to participate in Ghana’s regulated gold value chain under the Foreign Off-Taker License regime. This procedure outlines the regulatory framework, licensing roadmap, and operational processes to ensure full legal conformity, transparency, and commercial confidence.

2. Overview of the GoldBod Act (2025)

The Ghana GoldBod Act, 2025 centralises oversight of all artisanal and small-scale mining (ASM) gold transactions under the Ghana Gold Board (GoldBod). The Act introduces a tiered licensing structure covering buyers, aggregators, and exporters, with enhanced compliance measures focused on transparency, traceability, and fiscal accountability.

Foreign entities may engage in gold offtake activities only through a Ghanaian-registered subsidiary holding a valid Foreign Off-Taker License issued by GoldBod. This license authorises the purchase and export of gold exclusively from licensed miners and aggregators.

3. Licensing Roadmap Overview

Step 1: Incorporation of a Ghanaian Entity

  • Register a local subsidiary with the Registrar General’s Department

  • Obtain Certificate of Incorporation

  • Declare foreign ownership structure

Step 2: GIPC Registration

  • Mandatory registration with the Ghana Investment Promotion Centre (GIPC)

  • Meet minimum capital requirements (currently USD 200,000 for wholly foreign-owned entities)

  • Obtain GIPC Certificate

Step 3: Banking & Tax Registration

  • Open a Ghanaian corporate bank account

  • Obtain a Tax Identification Number (TIN) from the Ghana Revenue Authority

Step 4: Foreign Off-Taker License Application

  • Submit application via the GoldBod Licensing Portal

  • Upload incorporation documents, GIPC certificate, TIN, director identification, and proof of funds

  • Pay applicable licensing fees

Step 5: KYC & Due Diligence

  • Submit certified KYC documents for directors and beneficial owners

  • Provide proof of address, banking references, and source of funds

  • Undergo AML and background screening

Step 6: Business Plan & Off-Take Strategy

  • Define sourcing volumes and target aggregators

  • Outline logistics, security, packaging, and export processes

  • Include ESG, risk mitigation, and traceability frameworks

Step 7: License Approval & Induction

  • GoldBod review period: approximately 30–45 business days

  • License validity: 12 months

  • Mandatory operational induction

Step 8: Post-Issuance Compliance

  • All transactions priced in Ghana cedis using Bank of Ghana reference rates

  • Quarterly reporting of volumes, assay results, and export documentation

  • Compliance audits and inspections as required

Step 9: Annual Renewal

  • Renewal initiated 60 days before license expiry

  • Updated KYC, financial records, and compliance history submitted

4. Sterling Shadow SL Ltd – Strategic Advisory Support

Sterling Shadow SL Ltd provides advisory and facilitation support across the full licensing and operational lifecycle, including:

  • Regulatory and licensing guidance

  • Business planning and off-take strategy development

  • ESG and responsible sourcing advisory

  • KYC and compliance readiness

  • Transaction structuring and operational coordination

  • Ongoing compliance monitoring and renewal support

5. Client Onboarding & Process Flow

Stage 1: Orientation & Pre-Qualification

  • Initial consultation to assess scope, timelines, and regulatory requirements

  • Submission of client profile, trade intent, and market focus

Stage 2: Documentation & Licensing Support

  • Review and preparation of incorporation, banking, and regulatory documents

  • Execution of advisory and confidentiality agreements

  • Guidance through the GoldBod Foreign Off-Taker License application process

Stage 3: Post-Licensing Trade Facilitation

Once licensed, Sterling Shadow SL Ltd supports clients with:

  • Transaction structuring and pricing alignment

  • Coordination of assay verification and documentation

  • Export compliance and logistics coordination

  • Ongoing operational and regulatory oversight

6. Why Ghana? Why Now?

  • Ghana is Africa’s leading gold producer with a well-established ASM sector

  • The GoldBod Act 2025 introduces transparency, traceability, and investor confidence

  • A clearly defined licensing pathway now enables compliant foreign participation

Conclusion

The GoldBod Act 2025 represents a new era of regulated, transparent gold trading in Ghana. Through structured advisory support, Sterling Shadow SL Ltd enables foreign off-takers to operate with regulatory integrity, operational clarity, and commercial confidence.

This procedure serves as a strategic gateway for compliant gold sourcing, ensuring alignment with Ghanaian law while supporting sustainable and responsible trade practices.