Ghana - Threat Assessment - 2020 Page of 1 10

Ghana 🇬🇭

Section 1 - Executive Summary

Grey Lists: Ghana is listed by FATF & has been added to the EU list (proposed to come into force on 1/10/20) based on identified strategic AML/CTF issues. Ghana is listed by the US as a “Country of Primary Concern” in respect of ML & FC.

NRA: Ghana published its fi rst National Risk Assessment (NRA) in 2016. The assessment rated stealing, drug trafficking, corruption, and tax evasion as “High”, with Fraud at “Medium High” and Human Trafficking at People Smuggling at “Medium” with Environmental Crime & Cybercrime highlighted too. The overall threat was rated as “Medium High.”

Organised Crime: According to the OC Index, Low Criminality - High Resilience. Criminality 4.89/10, (ranked 26th of 54 African countries). Main markets are illegal mining (7.5/10), cannabis (7/10), heroin (6/10), cocaine (5.5/10) and synthetics (5.5/10). The main “Criminal Actors” are “State Embedded Actors” (6.5/10), “Criminal Networks’ (6/10), “Foreign Actors”(5/10) and “Mafia Style Groups”(1/10).

Corruption: TI CPI - 2019 - ranked 80/198, with a score of 41/100, a deterioration from 2016, where Ghana had a score of 43/100.

Modern Slavery: The 2018 GSI Index - 38/51 African countries, with 133,000 modern day slaves, and an incidence of 4.8/1000 people

and a “CC” response. US Trafficking in Persons - Tier 2 rating.

Sanctions & Terrorism: There are no sanctions against the country. Ghana is a Tier 2 (Moderate threat), PPI 2019 (Proliferation) Index country with a “Moderate” response score of 518/1,300. Ghana has a “Very Low” impact score (1.559/10) in the Global Terrorism Index 2019. Ghana isn’t included in US Country Reports on Terrorism.

Response & Resilience: FATF MER 4th round results by ESAAMLG scored Ghana at 73/100 for technical compliance (40 Recommendations), & 18/100 for effectiveness (11 Outcomes). Ghana scored 5.46/10 for resilience (Low), ranked 10/54 in Africa in the OC Index.

Indices: Ghana scored 82/100 and was rated “free” in the 2019 Freedom in the World report, and 59.4/100 for economic freedom (Heritage Foundation) described as “mostly unfree”. The Mo Ibrahim Index of African Governance (IIAG) scored Ghana 6th in Africa at 68.1/100. The Basel AML Index 2019 ranked Ghana with a score of 5.24/10.

Overall Ratings: Ghana is rated the 10th best rated country in SSA (out of 40) and 2/14 in West Africa, with an overall score of 55/100 “Moderate” risk, 59/100 “Moderate” level for Threats and 50/100 “Moderate-High” level for Responses, with an “Improving” trend.

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FCN Rating:”Moderate” Risk 55/100 “Improving”

https://www.giaba.org/media/f/996_GHANA%20NRA%20REPORT%202016%20-%20PUBLIC%20VERSION.pdf

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2. Country Information

People & Geography: Ghana is located in West Africa, in the centre of the Gulf of Guinea and borders with the Ivory Coast, Burkina Faso and Togo. Ghana is geographically closer to the ‘centre’ of the earth than any other country (closets to 0 degree Longitude & 0 degree Latitude) and as such experiences a tropical climate. Ghana is a beautiful country, endowed with natural resources. It encompasses plains, coastal shrub lands, beaches, forests, waterfalls and lakes (it’s most famous being Lake Volta - the largest artificial lake in the world). Ghana’s capital, Accra, is the most densely populated city in Ghana, and serves as the administrative, economic, legislative and judicial centre for the country. Of it's 29.8 million population, Ghana counts some 466,800 migrants for 2019, and 970,600 emigrants.

Recent History & Leadership: Ghana gained independence in 1957 with Kwame Nkrumah as it’s president. Ghana was the first country in Sub-Saharan Africa to break away from colonial rule, however, the period from 1960 onwards was marked by various military coups, economic stagnation and unstable governments. From 2000, whilst still facing some violent clashes, the government took positive steps to aid economic prosperity - such as the merging of two gold mining firms in 2003, and investing in the oil industry in 2007. In 2011, John Atta Mills became president, representing the National Democratic Congress party and was succeeded by John Mahama in 2012. Mahama was eventually replaced in 2017 by Nana Akufo-Addo, who is the current president.

Economy & Trade: In 2017, the GDP was USD47.02 billion, which represents 2.9% of the SSA economy. The government revenues amount to USD 9.544 billion. The GDP per capita in 2017 was USD4,700. Ghana’s

economy is made up of agriculture 18.3%, industry 24.5%, services 57.2%. These sectors encompass the mining, lumbering, light manufacturing, aluminium smelting, food processing (cocoa, rice, peanuts, corn, bananas) as well as financial services, information and communications technology, education, hospitality and property development. Ghana exports oil, gold, cocoa, timber, tuna, aluminium and diamonds to India (23.8%), UAE (13.4%), China (10.8%), Switzerland (10.1%), Vietnam (5.2%) & Burkina Faso (4%) - 2017. The country imports capital equipment, refined petroleum and foodstuffs from China (16.8%), US (8%), UK (6.2%), Belgium (5.9%) & India (4.1%) - 2017.

Environment: According to the Environmental Performance Index, Ghana is ranked 124/180 countries, with a score of 49.66/100.

Tourism: Travel & tourism contributed GHC17,497.3 million (US$3,305.1 million) in 2019, which represents 5% of the GDP of Ghana. The labour force for this sector is more than 623,100 people in direct employment, which represents 5.2% of the total employment rate in country. Some of the main tourist sites include Elmina Castle, Kakum National Park and Lake Volta.

Finance: In terms of remittances, the country has estimated inflows of US$3.521 billion (5.2% of the GDP) for the year 2019 and according to the World Bank. Connectivity-wise, there is an internet penetration rate of 48% and 39.97 million mobile connections for the year 2020. With regard to access to the banking system, 42% of the population (over 15 years of age) hold bank accounts, 5.8% have a credit card, and 39% have a mobile money account (2020).

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https://migrationdataportal.org/data?focus=profile&i=stock_abs_&t=2019&cm49=288https://www.cia.gov/library/publications/the-world-factbook/geos/gh.htmlhttps://epi.envirocenter.yale.edu/epi-indicator-report/EPIhttps://epi.envirocenter.yale.edu/epi-indicator-report/EPIhttps://www.wttc.org/economic-impact/country-analysis/country-data/https://www.knomad.org/sites/default/files/2020-04/Remittance%20inflows%20April%202020.xlsxhttps://datareportal.com/reports/?tag=Africahttps://datareportal.com/reports/?tag=Africa

3. Country Ratings

Available information from leading sources produce over 60 ratings for Ghana, covering both threats and responses in fighting financial crime, sanctions, proliferation finance and terrorism & terrorism finance.

Source Uganda Source Uganda Source Uganda

World Economic Forum Organised Crime Index

59.7 / 100 Transparency International (TI) Corruption Perceptions Index

41/ 100 (80/198)

Proliferation Index - PPI Threat

Tier 2 Moderate Threat Level

OC Index Criminaility

4.89/10 TI & Afrobarometer Citizens Views and Experiences of Corruption

Report

33% Overall Bribery Rate

Proliferation Index - PPI Controls

518/1300 Controls score

OC Index Criminal Actors

4.63/10 TRACE Bribery Risk Matrix

48 (80/200)

Global Terrorism Index GTI - Impact

1.559/10 “Very Low” Impact

OC Index State Embedded Actors

6.5/10 Global Slavery Index GSI Incidence

4.8/1,000 Incidence of human trafficking

US Dept of State Country Reports on Terrorism

Not Included

OC Index Criminal Networks

6.0/10 Global Slavery Index No of estimated Modern Day Slaves

133,000 Estimated numbers of modern day

slaves

Global Cybersecurity Index 2018

0.437/10 (89/175)

OC Index Foreign Actors

5.0/10 Global Slavery Index Country Response Rating

“CC” Rating (Ratings: AAA, AA, A etc)

Mo Ibrahim Governance Index (49.9 - All Africa)

68.1/100 (Increasing improvement) (6/54)

OC Index Mafia Style Gangs

1.0/10 US Dept of Labor Child Labour

1,721,914 - 24.7% of children aged between 5 -14 working

Freedom House Freedom Index

82/100 “Free”

OC Index Drugs Trafficking

Cannabis 7/10 & Heroin 6/10 Synthetic’s 5.5/10 & Cocaine 5.5/10

US Dept of State Trafficking in Persons

Tier 2 Rated Heritage Foundation Economic Freedom Index

59.4/100 “Mostly unfree”

OC Index Arms Trafficking

3/10 IOM Migration E - Emigration / I - Immigration

I -466,800/E - 970,600 Basel AML Index 5.24/10 60/125)

OC Index People Smuggling

4.5/10 Illegal Unreported and Unregulated (IUU) - IUU Fishing Index

1.98 (133/152)

FIU Egmont Member

Yes

OC Index Human Trafficking

4/10 EU Listing of Countries for Illegal Fishing

No Interpol Member

Yes

OC Index Illegal Timber

4.5/10 US DoS - Wildlife Trafficking Focus / Countries of Concern

Not Included Asset Confiscations over 1% of Proceeds

No

OC Index Illegal Wildlife

4/10 Environment Performance Index 49.66/100 124/180

Country National Risk Assessment

Yes

OC Index Illegal Mining

7.5/10 EUIPO & OECD Counterfeit Goods Propensity of Exports

0.157 (2016)

Financial Information Sharing Partnership

No

OC Index Resilience

5.46/10 Tax Justice Network Financial Secrecy Index

52 (117/133)

US Dept of State INCSR Vol I & Vol II

Yes

OC Index AML

6/10 EU List of None Co operative Jurisdictions for Tax purposes

Not Included European Union List Yes (Comes into force on 1/10/20)

OC Index Law Enforcement

6/10 OECD - Global Forum on Transparency & Exchange Info for Tax Purposes

Partially Compliant FATF Standards 40 Recommendations

73/100

OC Index International Co- operation

6/10 Global Financial Integrity Illicit Financial Flows

US$2.2 billion - 29.27% (2017) FATF Standards 11 IO’s on Effectiveness

18/100

OC Index Economic Regulatory Environment

6.5/10 Embassy’s from N Korea, Syria, Iran or Cuba

Cuba FATF Standards Core 10 Recommendations

73/100

Illegal Drug Dependency / Disorders Number/Share

184,002/0.63% Embargoes - Country Sanctions (Comprehensive - UN, US, EU, UK)

None FATF Standards Core 4 IO’s on Effectiveness

17/100

Numbeo Crime Survey 2020 48.97/100 (45/129)

OFAC Listed Parties with Local Addresses

2 FATF Counter - Measures

Strategic Deficiencies List

Yes (Strategic Deficiencies)

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https://reports.weforum.org/global-competitiveness-report-2018/competitiveness-rankings/https://www.transparency.org/en/cpi/2019/resultshttps://isis-online.org/uploads/isis-reports/documents/ThePeddlingPerilIndex2019_POD.pdfhttps://ocindex.nethttps://afrobarometer.org/sites/default/files/publications/Publications%20conjointes/partenaires/ab_r7_global_corruption_barometer_report.pdfhttps://isis-online.org/uploads/isis-reports/documents/ThePeddlingPerilIndex2019_POD.pdfhttps://ocindex.nethttps://www.traceinternational.org/trace-matrixhttp://visionofhumanity.org/app/uploads/2019/11/GTI-2019web.pdfhttps://ocindex.nethttps://www.globalslaveryindex.org/2018/findings/regional-analysis/africa/https://www.state.gov/country-reports-on-terrorism-2/https://ocindex.nethttps://www.globalslaveryindex.org/2018/findings/regional-analysis/africa/https://www.itu.int/dms_pub/itu-d/opb/str/D-STR-GCI.01-2017-PDF-E.pdfhttps://ocindex.nethttps://www.globalslaveryindex.org/2018/findings/regional-analysis/africa/http://iiag.onlinehttps://ocindex.nethttps://www.dol.gov/agencies/ilabhttps://freedomhouse.org/countries/freedom-world/scoreshttps://ocindex.nethttps://www.state.gov/wp-content/uploads/2019/06/2019-Trafficking-in-Persons-Report.pdfhttps://www.heritage.org/index/rankinghttps://ocindex.nethttps://migrationdataportal.org/data?i=stock_abs_&t=2019https://www.baselgovernance.org/sites/default/files/2019-08/Basel%20AML%20Index%202019.pdfhttps://ocindex.nethttps://globalinitiative.net/iuu-fishing-index/https://egmontgroup.org/en/membership/listhttps://ocindex.nethttps://www.interpol.int/en/Who-we-are/Member-countrieshttps://ocindex.nethttps://www.state.gov/2019-end-wildlife-trafficking-report/https://ocindex.nethttps://epi.envirocenter.yale.edu/epi-indicator-report/EPIhttps://www.fia.go.ug/sites/default/files/2019-12/Money%20Laundering%20And%20Terrorist%20Financing%20National%20Risk%20Assessment%20Report_1.pdfhttps://ocindex.nethttps://www.oecd-ilibrary.org/docserver/g2g9f533-en.pdf?expires=1590589653&id=id&accname=guest&checksum=A3665F2B6E50E1C180C9461ECFAEF247https://ocindex.nethttps://fsi.taxjustice.net/en/introduction/fsi-resultshttps://www.state.gov/wp-content/uploads/2020/03/Tab-1-INCSR-Vol.-I-Final-for-Printing-2-25-20-508.pdfhttps://www.state.gov/2020-incsr-volume-ii-money-laundering-and-financial-crimes-as-submitted-to-congress/https://ocindex.nethttps://www.consilium.europa.eu/en/policies/eu-list-of-non-cooperative-jurisdictions/https://thefinancialcrimenews.com/eu-commission-high-risk-third-countries-must-do-better/https://ocindex.nethttps://www.oecd.org/tax/transparency/exchange-of-information-on-request/ratings/http://www.fatf-gafi.org/publications/mutualevaluations/documents/assessment-ratings.htmlhttps://ocindex.nethttps://gfintegrity.org/report/trade-related-illicit-financial-flows-in-135-developing-countries-2008-2017/http://www.fatf-gafi.org/publications/mutualevaluations/documents/assessment-ratings.htmlhttps://ocindex.nethttps://embassy-finder.comhttp://www.fatf-gafi.org/publications/mutualevaluations/documents/assessment-ratings.htmlhttps://ourworldindata.org/grapher/number-with-drug-use-disorders-countryhttps://ourworldindata.org/illicit-drug-usehttps://www.knowyourcountry.com/copy-of-country-reportshttp://www.fatf-gafi.org/publications/mutualevaluations/documents/assessment-ratings.htmlhttps://www.numbeo.com/crime/rankings_by_country.jsp?title=2020&displayColumn=0https://sanctionssearch.ofac.treas.govhttp://www.fatf-gafi.org/publications/high-risk-and-other-monitored-jurisdictions/documents/increased-monitoring-february-2020.html

4. Financial Crime News (FCN) Country Ratings

From all the available information collected and results summarised in Section 3 above, 20 plus ratings have been selected, covering a broad base of threats and responses in fighting financial crime, sanctions, proliferation finance, terrorism & terrorism finance. The results make up the FCN Country Threat / Response & Overall Risk scores and rankings for countries in Sub-Saharan Africa.

Ratings across Sub-Saharan Africa, compared to other countries:

FCN Final Ratings - Ghana 🇬🇭 Financial Crime News

Threat Rating 59/100

“Moderate” ThreatFinancial Crime News Financial Crime Rating

55/100 “Moderate” Risk 10/40 SSA - 2/14 WA

Financial Crime News Response Rating

50/100 “Moderate-High” Response

Trend (TI CPI, Mo Ibrahim, FATF, Basel Index & GTI - 3-5 years)

Improving

For more details on the scoring model for FCN Ratings contact the Editor FCN directly for access to the Methodology

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FCN SSA Country Risk Rating - “Moderate” Threats - 🇬🇭

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5. Selected Information

From the available information, a number of indicators can be tracked over time to identify trends. A number of these indicators are identified below together with additional charts used in the Long Form “Deep Dive” Country Threat Assessment for Ghana, coming soon, available from Financial Crime News/Premium.

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The Authors of this work is John Cusack. Data Investigation & Information collection by Hannah Cusack. The Editor is John Cusack, the publisher is Financial Crime News / Metriqa Limited. All rights remain with FCN/Metriqa Limited.

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6. Appendix - FATF Results in Detail

The FATF MER 4th round results by ESAAMLG scored Ghana at 73/100 for technical compliance (40 Recommendations), & 18/100 for effectiveness (11 Outcomes). The poor ratings originally allocated in relation to Immediate Outcomes subsequently resulted in FATF including Ghana on the FATF list of “Jurisdictions under Increased Monitoring” in October 2018. The latest results are set out below. According to FATF, “Ghana should continue to work on implementing its action plan to address its strategic deficiencies, including by: (1) implementing a comprehensive national AML/CFT Policy based on the risks identified in the NRA, including measures to mitigate ML/TF risks associated with the legal persons; (2) improving risk-based supervision, by enhancing the capacity of the regulators and the awareness of the private sector; (3) ensuring the timely access to adequate, accurate and current basic and beneficial ownership information; (4) ensuring that the FIU is focusing its activities on the risks identified in the NRA, and adequately resourced; and (5) applying a risk-based approach for monitoring non-profit organisations.”

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http://www.fatf-gafi.org/publications/high-risk-and-other-monitored-jurisdictions/documents/increased-monitoring-february-2020.html#ghana

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