Ghana is a founding member of the World Trade Organisation (WTO) but not a party to any of the plurilateral agreements concluded under its framework, including the Agreement on Government Procurement and the Information Technology Agreement. Plurilateral agreements negotiated within the WTO are binding only on the members that choose to sign and ratify them rather than on the entire WTO membership.

Ghana is, however, a party to the first multilateral agreement reached since the establishment of the WTO – the Trade Facilitation Agreement (TFA), which it ratified on 4 January 2017. The TFA aims to simplify and modernise customs procedures to facilitate the smooth movement of goods across borders, a particularly significant development for developing and least-developed countries seeking to enhance trade efficiency and competitiveness.

Ghana also recently accepted the Agreement on Fisheries Subsidies on 2 July 2025, the second multilateral agreement concluded after the TFA. This Agreement represents a collective effort by member states of the WTO to curb subsidies that contribute to illegal, unreported, unregulated (IUU) fishing and overfishing in order to promote sustainable use of marine resources and long-term environmental conservation.

Ghana is party to multiple regional and preferential (free trade) agreements both at the continental and intercontinental levels. The key free trade agreements are as follows.

The African Continental Free Trade Area (AfCFTA)

The AfCFTA, a flagship initiative of the African Union’s Agenda 2063, was established to create a single continental market of nearly 1.3 billion people with a combined GDP of over USD3.4 trillion. Entering into force on 30 May 2019, it is the world’s largest free trade area by participating countries. The AfCFTA Agreement includes Protocols on:

• Trade in Goods;
• Trade in Services;
• Investment;
• Intellectual Property Rights;
• Competition Policy;
• Dispute Settlement;
• Women and Youth in Business; and
• Digital Trade.

Ghana hosts the AfCFTA Secretariat, positioning it as a strategic hub for continental trade integration and policy co-ordination.

Economic Community of West African States (ECOWAS)

Ghana is a founding member of ECOWAS, created in 1975 to foster economic integration and co-operation among West African states. ECOWAS operates a Free Trade Area and Customs Union facilitating free movement of goods, services and people. Through the ECOWAS Trade Liberalisation Scheme (ETLS), approved goods of origin move duty-free across member states. Ghana actively contributes to shaping regional trade policy within ECOWAS to advance shared economic objectives.

EU–Ghana Interim Economic Partnership Agreement (Interim EPA)

In 2007, Ghana concluded the Interim EPA with the European Union, a goods-only reciprocal free trade agreement under WTO rules ratified in 2016. Covering about 78% of Ghana’s tariff lines, the Interim EPA ensures continued preferential access for Ghanaian exports while gradually liberalising EU goods. The EU remains Ghana’s largest trading bloc and key destination for non-traditional exports.

United Kingdom–Ghana Trade Partnership Agreement (UK–Ghana TPA)

Following the UK’s withdrawal from the EU, Ghana and the UK signed a UK–Ghana TPA in 2021. Mirroring the EU–Ghana EPA, it grants duty-free, quota-free access for Ghanaian exports to the UK, while Ghana commits to phased tariff liberalisation. The TPA promotes investment, regional integration and balanced participation in the global economy, aligning with Ghana’s national development priorities and WTO principles.

Generalised System of Preferences

Ghana benefits from non-reciprocal preferential arrangements such as the Generalised System of Preferences (GSP). The GSP schemes are autonomous preferential arrangements under which developed countries, including Japan, Canada and Turkey, grant non-reciprocal tariff preferences to developing countries on a wide range of eligible products. It is instructive to note that although GSP arrangements are not legally binding on Ghana, they play an important role in enhancing the competitiveness of Ghanaian exports in key markets by lowering import costs for buyers abroad.

To qualify for these preferences, Ghanaian exporters must comply with certain conditions such as product-specific rules of origin, documentation requirements, and other eligibility criteria. By participating in GSP schemes, Ghana is able to diversify its export markets, promote value added production, and support the growth of non-traditional export sectors such as processed agricultural and manufactured goods.

African Growth and Opportunity Act

Ghana benefited under the African Growth and Opportunity Act (AGOA), a non-reciprocal preferential trade arrangement enacted by the United States. The future of the AGOA is currently uncertain following its statutory expiration on 30 September 2025. The AGOA served as a central pillar of US–Africa trade relations, granting eligible African countries, including Ghana, duty-free entry into the US market for more than 6,000 product lines.

As disclosed by the government, negotiations are ongoing between Ghana and China to finalise a zero-tariff trade agreement. Under this proposed deal, Ghanaian exports would gain tariff-free access to the Chinese market, potentially boosting trade volumes and strengthening bilateral economic ties. The arrangement is still in the negotiation phase and the legal text is yet to be published and formally ratified.

ECOWAS

ECOWAS experienced a regional shock when three ECOWAS member states – Burkina Faso, Mali and Niger – announced their formal exit from the regional bloc, with effect from January 2025.

Why the reconfiguration matters for Ghana

The reconfiguration affects regional trade architecture in relation to the mechanism for duty-free trade established through the ECOWAS Trade Liberalisation Scheme, as well as the Common External Tariff and cross-border movement. It raises practical questions about continuity of trade facilitation within the bloc.

AfCFTA Negotiations and Implementation

Over the next 12 months, key developments are expected in AfCFTA negotiations, particularly concerning the annexes on dispute settlement under the Investment Protocol and the Intellectual Property Rights Protocol. These measures will enhance legal certainty, investor protection, and trade facilitation across Africa. Implementation efforts will also intensify, including tariff liberalisation and rules of origin negotiations, with the phase-down for Category B sensitive goods scheduled to commence on 1 January 2026 to support meaningful intra-African trade expansion.

Implementation of WTO Agreement on Fisheries Subsidies

The WTO Agreement on Fisheries Subsidies, effective September 2025, will enter its critical implementation phase. Ghana will need to co-ordinate between trade and fisheries authorities to comply with prohibitions on subsidies contributing to illegal, unreported and overfishing, while maintaining support for sustainable livelihoods. The Agreement introduces enhanced transparency, notification and enforcement obligations that will guide fisheries management and cross-border trade in fishery products.

Future of the AGOA

Following the expiry of the AGOA in September 2025, Ghana faces uncertainty regarding duty-free access to the US market. Unless the programme is renewed or extended, imports from eligible African countries will be subject to a different tariff schedule, directly affecting Ghana’s export competitiveness, trade policy planning, and engagement with US trade and investment initiatives.

The key authorities that govern customs matters in Ghana include the Ghana Revenue Authority, Ministry of Finance, Ministry of Trade Agribusiness and Industry, and the Ghana Ports and Harbours Authority. The legal framework governing customs matters is mainly captured under the Customs Act, 2015 (Act 891) (as amended), and the Customs Regulations, 2016 (LI 2248). 

The Customs Division of the Ghana Revenue Authority is the key government body that administers and enforces customs laws. It operates in close co-ordination with the Ministry of Trade, Agribusiness and Industry.

Under the EU Trade Barriers Regulation (TBR) and Section 301 of the US Trade Act of 1974, the EU and US, respectively, are empowered to investigate and respond to foreign trade practices that are deemed unfair or discriminatory against their interests. The EU TBR emphasises multilateral enforcement via the WTO dispute settlement system, while the US Trade Act provides broader authority for unilateral action, including the imposition of trade sanctions.

Under the Ghana International Trade Commission Act, 2016 (Act 926), domestic firms in Ghana can petition the Ghana International Trade Commission (GITC) to initiate, or GITC can on its own initiate, investigations on matters related to anti-dumping, countervailing, safeguard and tariff review. These proceedings are ad-hoc and complaint-driven in nature. The primary aim of this Act is to provide a domestic mechanism for import-remedies, tariff reviews, classification or valuation appeals and other special import measures to protect domestic industry.

The Act does not explicitly state whether non-domestic companies can initiate petitions or participate in the process. However, the use of words such as “affected persons”, “interested persons” and “interested parties”, under Sections 25, 34, 35 and 41, suggests that non-domestic companies are allowed to initiate proceedings, make representations or participate as interested parties. After GITC makes a decision, Sections 39 and 50 of the Act require GITC to publish that decision in the Gazette.

It must be noted that, in the stricter sense, Ghana does not yet have a broad export-side trade-barrier instrument equivalent in scope to the EU TBR or Section 301 of the US Trade Act. In essence, the state is not clothed with statutory authority to investigate and unilaterally retaliate specifically against discriminatory foreign market-access measures outside the WTO or multilateral regional framework. For export-side grievances, Ghana therefore relies primarily on WTO dispute settlement, diplomatic channels and other regional frameworks such as the AfCFTA and ECOWAS.

GoldBod

From a customs perspective, the establishment of the Ghana Gold Board (GoldBod) under the Ghana Gold Board Act, 2025 (Act 1140) represents a major regulatory shift in the governance of gold exports, particularly from the artisanal and small-scale mining sector. GoldBod is now vested with exclusive authority to license, purchase, assay, grade and export gold produced by licensed small-scale miners. The Act prohibits unlicensed trading or export of artisanal gold and restricts foreign participation. The GoldBod framework integrates export controls, traceability and compliance into the broader clearance process, requiring gold exports to pass through approved GoldBod channels for valuation, documentation and certification prior to customs release.

Legally, GoldBod’s creation consolidates regulatory and operational powers within a single statutory body, aligning with Ghana’s broader objective of curbing gold smuggling, improving revenue collection, and ensuring full repatriation of foreign exchange proceeds. Its mandate introduces binding compliance obligations on exporters and buyers. Engaging in gold trading or export activities without a valid licence constitutes an offence, punishable by a fine ranging from GHS600,000 to GHS2.4million, or by imprisonment for a term of five to ten years.

BOG Directive on Declarations

In August 2025, the Bank of Ghana (BOG) amended the guidelines on the importation and exportation of foreign currency, effective 1 September 2025, under the following:

• the Customs Act, 2015 (Act 891);
• the Foreign Exchange Act, 2006 (Act 723); and
• the Anti-Money Laundering Act, 2020 (Act 1044).

The amendment requires travellers to declare, upon entry or exit, any amount exceeding USD10,000 or its equivalent in the following:

• monetary instruments such as
1. cash,
2. coins,
3. travellers’ cheques,
4. personal and cashier’s cheques,
5. bearer shares, and
6. bonds; and
• precious metals or stones.

Importers are also required to support their transactions with endorsed foreign exchange bureau receipts or bank slips, together with valid import documentation such as an Import Declaration Form, commercial invoice and, where applicable, a contract. Failure to make declarations or provide the required documentation will result in fines, criminal prosecution or the immediate seizure of undeclared amounts.

Over the next 12 months, a key customs and trade policy issue will be the government’s proposed restrictions on the importation of goods that can be produced locally. While the policy is intended to protect domestic manufacturing, curb the dumping of substandard products and promote industrial growth, it raises important legal considerations under Ghana’s multilateral and regional trade obligations. In particular, any measures imposing quantitative or discriminatory restrictions on imports will need to be carefully designed to remain consistent with WTO Agreements and the ECOWAS Trade Liberalisation Scheme, ensuring that legitimate industrial policy objectives are balanced against Ghana’s binding commitments on market access and non-discrimination.

The Attorney-General of Ghana is empowered under the Anti-Terrorism (Amendment) Act, 2012 (Act 842), specifically under Section 37A, to issue instructions through an Executive Instrument for the purpose of preventing and suppressing terrorism and financing of terrorists in pursuance of the United Nations Security Council (UNSC) sanctions resolutions. By an Executive Instrument dated 15 February 2013 (the EI), the Attorney-General issued instructions and established an Inter-Ministerial Committee responsible for the implementation of the UNSC sanctions resolutions. Through this mechanism, Ghana enforces binding multilateral sanctions against designated states, entities and individuals, including the following:

• arms embargoes;
• asset freezes;
• trade and financial restrictions; and
• travel bans.

Beyond the UN framework, Ghana’s regime also covers regional sanctions adopted under the Economic Community of West African States (ECOWAS) framework, such as collective measures imposed in response to unconstitutional changes of government or regional security threats. The AfCFTA Agreement, pending full implementation, will also play a role in Ghana’s sanctions regime.

Under the EI, the key authorities responsible for imposing sanctions, specifically in the context of anti-terrorism, include:

• Ministry responsible for Foreign Affairs;
• Attorney-General;
• Bank of Ghana; and
• Securities and Exchange Commission.

The relevant government agencies responsible for administering and enforcing the sanctions regime are:

• Attorney-General;
• Ministry responsible for Foreign Affairs;
• Bank of Ghana;
• National Insurance Commission;
• Securities and Exchange Commission;
• Customs Division of the Ghana Revenue Authority;
• Ghana Immigration Service;
• Ghana Real Estate Developers Association;
• General Legal Council;
• Institute of Chartered Accountants;
• Gaming Commission;
• Financial Intelligence Centre;
• Narcotics Control Commission;
• Economic and Organised Crime Office;
• Ghana Police Service;
• National Security Council Secretariat; and
• other institutions as determined by the Attorney-General.

Ghana’s sanctions laws and regulations apply to all natural and legal persons within the jurisdiction, as well as persons covered under multilateral and regional agreements such as the UN, AfCFTA and ECOWAS. These persons include:

• individuals and entities located, incorporated or operating in Ghana;
• financial institutions and designated non-financial businesses;
• Ghanaian nationals and companies abroad; and
• persons whose conduct falls within the scope of UN, ECOWAS or AfCFTA sanctions.

The sanctions framework in Ghana makes provision for lists of sanctioned persons to be maintained in line with the UNSC sanctions regime. The Interpretation Section of the EI defines a Domestic List as the list of individuals, entities or organisations identified as terrorists or terrorist organisations, engaging in the financing of terrorism or terrorist organisations, or engaging in the financing of the proliferation of weapons of mass destruction and other transnational organised crime prepared and approved by the Inter-Ministerial Committee established under the EI.

The EI also authorises the dissemination of the United Nations Sanctions List. The Minister responsible for Foreign Affairs is required to transmit to the Attorney-General the listing or delisting of any individual or organisation by the UNSC in accordance with Chapter VII of the UN Charter. The Attorney-General is also mandated to disseminate the information contained in the list to the designated authorities, including the Ghana Immigration Service and Financial Intelligence Centre, among others, to cause the listing or delisting of any individual or organisation which is to be published in a Gazette. It is worth noting that these do not constitute an autonomous sanctions regime or independent foreign policy measure as found in other jurisdictions. 

Ghana does not have comprehensive sanctions and broad embargoes against other countries. Instead, Ghana implements targeted import restrictions, such as bans on specific products like narcotics, contaminated food and dangerous weapons, and illegal activities such as illegal mining.

Generally, Ghana has no autonomous sanctions lists. However, it applies a few non-list-based and regulatory sanctions measures within its domestic legal framework, particularly in areas such as financial compliance, anti-terrorism under the state’s anti-terrorism regime, and import restrictions or bans in the area of trade.

Ghana does not apply or threaten secondary sanctions, which are sanctions imposed on transactions with no nexus to Ghana’s jurisdiction, as is characteristic of secondary sanctions typically used by larger economies.

Ghana enforces a strict liability approach for breaches of sanctions, with both individuals and entities being subject to criminal prosecution, penalties and regulatory sanctions for non-compliance, under the Anti-Terrorism Act, the Anti-Money Laundering Act and related laws.

Ghana does not have a licensing regime for activities otherwise prohibited under sanctions laws or regulations.

Ghana’s sanctions compliance regime requires strict adherence to UN Security Council sanctions and domestic designations. Accountable institutions, including banks, insurers and other financial institutions, must screen customers and transactions against UN and domestic sanctions lists, freeze the funds or assets of designated persons or entities as may be directed by the authorities or the courts, and report such actions to the FIC without delay. Institutions must maintain detailed records, implement internal controls and training to prevent circumvention, and co-operate fully with regulatory authorities.

Standards of Liability

Liability for non-compliance applies to both institutions and individuals. Directors and officers of corporate entities may also be held personally liable. Ghana’s framework therefore imposes a strict duty of due diligence, aligning with global AML/CFT and counter-proliferation standards to ensure effective implementation of sanctions obligations.

Financial institutions and businesses are required to comply with AML and CFT reporting obligations under the AML Act and related Bank of Ghana directives as it relates to the UN sanctions regime. The Financial Intelligence Centre is required to disseminate the UN Consolidated List without delay to the relevant financial institutions and competent authorities, and take such measures that are necessary for the enforcement of the UN Consolidated List. Some of these measures may include freezing and blocking assets. For instance, Section 5 of the Anti-Terrorism Act provides that a person holding the funds of a terrorist, financier of terrorism, or terrorist organisation, as designated by the UN Security Council, shall freeze those funds upon an order to that effect from the High Court, and also report the existence of the funds to the FIC.

Ghana does not have any blocking statutes, anti-boycott regulations or specific legal provisions that prohibit adherence to third-country sanctions.

There have not been any notable developments regarding sanctions in Ghana over the past 12 months. A review of the international sanctions regime over the past 12 months does not show that Ghana has been directly implicated in sanctions evasion or proliferation financing (PF)-related transactions or related offences.

Over the next 12 months, Ghana’s exposure to sanctions risks could primarily arise from evolving international measures by major partners such as the United States of America, European Union and United Kingdom. These jurisdictions are broadening export controls on critical minerals, technology and dual-use goods, as well as expanding anti-circumvention rules that could indirectly affect Ghanaian exports or transshipments involving sanctioned regions. Although Ghana is not directly targeted, its role as a regional trading and financial hub means that exporters, logistics operators and banks must navigate heightened compliance expectations in cross-border transactions.

Multilateral developments, including new UN and FATF initiatives on proliferation financing and trade-linked money laundering, are likely to increase scrutiny of financial flows linked to trade. To mitigate these risks, Ghanaian authorities and businesses will need to enhance due diligence, end-user verification and sanctions screening systems. Strengthening co-ordination among trade and financial regulators will be key to maintaining global market access and ensuring continued alignment with international sanctions standards.

Ghana’s export control framework governs the export of specific goods, technologies and services to safeguard national security, fulfil international obligations and prevent illicit trade. One of the key legislations is the Export and Import Act, 1995 (Act 503), which empowers the Minister responsible for Trade, under Sections 12 and 13, to prohibit or restrict the export of specified goods. The Minister exercises this power through legislative instruments, such as the Export and Import (Restrictions on Exportation of Grains) Regulations, 2022 (LI 2467), and the Export and Import (Restrictions on Exportation of Soya Bean) Regulations, 2020 (LI 2432).

Enforcement of the restrictions at borders and ports are carried out under the mandate of institutions such as the Ghana Revenue Authority (GRA) in line with the Customs Act, 2015 (Act 891) and the Customs Regulations, 2016 (LI 2248). In addition, specialised agencies also oversee sector-specific export controls, including the Centre for Import and Export Control (CIEC) of the Food and Drugs Authority (FDA), as mandated under Sections 99 and 118 of the Public Health Act, 2012 (Act 851), to regulate the exportation of the following:

• food;
• drugs;
• cosmetics;
• household chemical substances;
• medical devices;
• tobacco and tobacco products; and
• biological products, including blood and blood derivatives.

The Ghana Export Promotion Authority (GEPA), established under the Ghana Export Promotion Authority Act, 1969 (NLCD 396), is responsible for the facilitation, development and promotion of Ghanaian exports while ensuring compliance with relevant export regulations. It acts as the national export trade support institution of the Ministry of Trade, Agribusiness, and Industry. Further, the Ghana Gold Board Act, 2025 (Act 1140) vests exclusive authority in the Ghana Gold Board (GoldBod) to buy, sell, weigh, grade, assay, value and export gold from Ghana, ensuring effective oversight and transparency in the gold trade.

Together, these laws and institutions form an integrated export control system aimed at ensuring that Ghana’s export activities align with national interests, public health and safety standards, and international regulatory commitments.

In Ghana’s export control regime, there is an inherent overlap between administrative and enforcement authorities, as some agencies perform dual functions – both in administration and enforcement within their respective mandates. Their administrative mandates include policymaking, regulation and licensing.

The key administrative authorities include:

• Ministry of Trade, Agribusiness and Industry;
• Ghana Export Promotion Authority;
• Ghana Standards Authority;
• Ghana Shippers Authority; and
• Ghana International Trade Commission.

Ghana’s export control framework also requires exporters to obtain specific sector-based permits or certificates from the relevant authorities, including the following:

• Ministry of the Interior;
• Ministry of Health;
• GoldBod;
• Ghana Cocoa Board;
• Forestry Commission;
• Ministry of Food and Agriculture;
• Food and Drugs Authority;
• Ghana Geological Survey Authority;
• Department of Game and Wildlife;
• Ministry of Food and Agriculture;
• Environmental Protection Agency;
• Ghana Museums and Monuments Authority; and
• Births and Deaths Registry.

As noted above, an overlap exists in the administrative and enforcement mandates of authorities engaged in the export controls regime. The government agencies enforcing export controls include:

• Ghana Revenue Authority;
• Ghana Ports and Harbours Authority;
• Ghana Maritime Authority; and
• Ghana Shippers Authority.

Both natural and artificial persons are subject to Ghana’s export controls. Export controls apply to persons engaged in the exportation of items, products or goods as governed by the export controls legal framework. Sections 1 and 6 of the Export and Import Act allow any person to export goods from Ghana once the relevant forms are submitted, or where the relevant certification, licences or permits are procured depending on the applicable law.

Ghana does not currently maintain an independent national list of restricted or prohibited persons for export control purposes. However, it implements restrictions and sanctions through its international and regional obligations, including under the ECOWAS and the UN, as discussed above.

Ghana does not maintain a single consolidated national list of sensitive exports, but it regulates and restricts specific categories of goods through various sector-specific laws. These restrictions are designed to protect national security, public health and the environment, and to comply with international obligations. The power to add prohibit and restrict the exportation of goods and products is vested in the Minister responsible for Trade under Sections 12 and 13 of the Export and Import Act.

There is a complete ban on the exportation of certain items such as:

• round log (12 species, including rosewood);
• narcotics/psychotropic substances;
• African grey parrots;
• endangered animal species;
• rattan canes and bamboo;
• obscene and pornographic materials; and
• any other goods prohibited by international laws.

Export restrictions on goods relate to restrictions on quantity or other specifications based on either international laws or sector-specific laws in Ghana. All restricted goods require certification or permits by the relevant agencies. This applies to both traditional and non-traditional export commodities. Restricted items include:

• arms and ammunition – export permit from the Ministry of the Interior;
• gold – export licence from GoldBod;
• cocoa, coffee, shea nuts, cashew nuts – export permit from Ghana Cocoa Board (COCOBOD);
• timber products – export permit from the Forestry Commission;
• manufactured/processed goods – export permit from Ghana Standards Authority;
• food and agricultural produce – certificate from the Ministry of Food and Agriculture;
• palm oil – export permit from the Plant Protection and Regulatory Services Directorate (PPRSD), Food and Drugs Authority;
• rock and soil samples – export permit from the Ghana Geological Survey Authority;
• wildlife – permit under the Convention on International Trade in Endangered Species (CITES) issued by the Department of Game and Wildlife;
• pets – export permit from the Veterinary Services Directorate, Ministry of Food and Agriculture;
• chemicals (including plant-based chemicals) – export permit from the Environmental Protection Agency;
• pharmaceuticals – export permit from the Ministry of Health and the Food and Drugs Authority;
• antiques – export permit from the Ghana Museums and Monuments Authority; and
• human remains – death certificate from the Births and Deaths Registry.

As discussed above, Ghana’s export control regime combines non-list based regulatory direction, licensing systems and case-by-case enforcement, allowing authorities to restrict exports based on evolving national interests, security and international obligations.

Penalties for violating Ghana’s export controls generally range from fines, imprisonment, suspension or revocation of export licences to forfeiture of goods, depending on the type of goods and the specific law breached. Enforcement is taken seriously, especially for strategic, restricted or security-sensitive exports, and both individuals and companies can be held criminally liable.

For instance, Section 14 of the Export and Import Act provides that any person who exports goods in contravention of any regulation made by the Minister responsible for Trade, knowingly makes a false declaration or contravenes any provision of the Act shall be liable to a fine and/or imprisonment. In addition to this, the goods in respect of which the offence was committed could be seized and forfeited to the state. Under the Customs Act, 2015, Section 121 similarly provides that a person who exports or is involved in illegally exporting any prohibited or restricted goods shall be liable to imprisonment, a fine and/or forfeiture of the goods.

Under Ghana’s export controls framework, licences may be issued to authorise the export of restricted items, but not for goods or activities that are expressly prohibited by law.

Compliance Expectations

Under Ghana’s export control framework, exporters are expected to fully comply with all applicable laws, regulations and permit requirements governing the export of goods, technology and services. As noted above, compliance obligations apply both to individuals and corporate entities, and liability may arise for intentional, negligent or unauthorised export activities.

Exporters are required to:

• obtain all necessary export permits or licences from the relevant regulatory authorities before shipment;
• ensure the accuracy and completeness of export documentation, including declarations submitted to the Ghana Revenue Authority;
• maintain proper records of export transactions for inspection by regulatory agencies;
• verify end-use and end-user information, particularly for restricted goods; and
• comply with financial and anti–money laundering regulations, ensuring that all export proceeds are remitted through authorised financial institutions in line with Bank of Ghana and Financial Intelligence Centre guidelines.

Standards of Liability

Standards of liability for violations of export controls are as follows.

• Under the relevant statutes and regulations such as the Export and Import Act and Customs Act, as discussed above, liability for violations may be criminal or administrative, depending on the nature of the offence.
• Corporate liability arises where violations are committed by officers, employees or agents acting within the scope of their duties. These persons may also be held personally liable in accordance with the applicable company law principles.
• Penalties may include:
1. fines,
2. imprisonment,
3. forfeiture of goods,
4. suspension or revocation of export licences, and
5. loss of trading privileges.

Ghana imposes export reporting requirements under the relevant laws to ensure transparency and regulatory oversight of export transactions. Sections 1, 2 and 3 of the Export and Import Act require exporters to provide to the Commissioner of Customs, Excise and Preventive Service prescribed information, including an Exchange Control Form A2 endorsed by a bank in Ghana for traditional export goods at the time of exportation, and a Ghana Export Form for non-traditional export goods.

A key recent development in Ghana’s trade and export control landscape is the proposed Export and Import (Restrictions on Importation of Selected Strategic Products) Regulations, 2023. The draft legislative instrument (LI) seeks to restrict the importation of about 22 items, including cement, sugar, canned tomatoes, soft drinks and mineral water, with the aim of protecting local industries and promoting self-sufficiency.

However, the proposal faced strong opposition in Parliament, with concerns that the restrictions could disadvantage traders, disrupt supply chains and trigger higher consumer prices. As a result, Parliament has suspended the laying of the LI to allow for broader consultations and stakeholder engagement. The measure remains one of the most closely watched trade policy developments in Ghana.

Export and Import (Restrictions on Exportation of Grains) Regulations, 2022 (LI 2467)

A major pending issue in Ghana’s export control regime is the possible review or repeal of the Export and Import (Restrictions on Exportation of Grains) Regulations, 2022 (LI 2467). The Ghana Soybean Farmers and Aggregators Association has renewed calls for the ban’s removal, arguing that it has failed to achieve its purpose of supporting local processors. Instead, it has left farmers with unsold surpluses and driven regional buyers to neighbouring countries such as Benin, Togo and Nigeria, undermining Ghana’s competitiveness in the soybean market.

The next 12 months will reveal whether the government will reconsider its grain export restrictions. Broader discussions are also emerging around agricultural input policies, including proposals to reduce or eliminate taxes and levies on fertiliser imports and local production to make them more affordable. These developments suggest a potential shift towards liberalising agricultural exports and improving the business environment for producers.

Export and Import (Restrictions on Importation of Selected Strategic Products) Regulations

In the coming months, attention will focus on whether the proposed Export and Import (Restrictions on Importation of Selected Strategic Products) Regulations, 2023 is revised, withdrawn or reintroduced after consultations. Key areas to watch include how the government balances its goal of protecting local industries with the need to maintain market stability and price competitiveness.

Stakeholders will also be monitoring whether future revisions introduce clearer criteria for selecting “strategic products”, transparent permit procedures and mechanisms to prevent supply shortages or inflationary pressures. The final outcome will likely signal Ghana’s broader policy direction on trade liberalisation versus protectionism, shaping the operating environment for importers, manufacturers and exporters over the next year.

The Ghana International Trade Commission (GITC) is the primary body that governs the Anti-Dumping and Countervailing regime in Ghana in line with the GITC Act, 2016 (Act 926). The Act is complemented by other laws such as:

• GITC Anti-Dumping Regulations, 2019 (LI 2380);
• GITC Customs Valuation Dispute Settlement Regulations, 2019 (LI 2382);
• GITC Subsidy and Countervailing Measures Regulations, 2020 (LI 2425); and
• GITC Safeguard Measures Regulations, 2020 (LI 2426).

The domestic legal framework reflects broader international principles under the WTO, which serves as the primary international body in this space. Section 2 of the Act provides that the Commission, in furtherance of its objects, is to be guided by the treaty provisions of the WTO and the general principles of international trade law.

The GITC, established by the Ghana International Trade Commission Act, 2016 (Act 929), is the primary domestic authority responsible for investigating and determining dumping, subsidy and safeguard cases under the Act 926 and its subsequent regulations. The Minister responsible for Trade imposes safeguard measures or tariff adjustment measures on the recommendation of the GITC. The Customs Division of the Ghana Revenue Authority is responsible for the collection of AD/CVD once imposed by the GITC.

Under Ghanaian law, the system is primarily complaint-driven. Domestic companies or their representatives have the right to petition GITC in line with Sections 34 and 35 of the GITC Act to initiate reviews of tariffs, safeguard measures or AD/CVD when there is a significant change. GITC is mandated to conduct periodic mid-term reviews when a definite safeguard has been imposed for a period of more than three years. It is also mandated to initiate sunset reviews every six months after imposing anti-dumping duties.

Domestic companies or their representatives may petition GITC for a review whenever there is a change in circumstance. The petition must be a written complaint from the domestic company, which must be a producer of products that are similar or directly competitive with the products that are the subject of complaint. The GITC itself conducts mandatory periodic reviews only when a measure is due to expire or if circumstances change, but petitions from domestic industries can be filed at any time when sufficient grounds exist.

Non-domestic companies are provided the opportunity to participate as interested parties in reviews that affect their exports by providing evidence which they consider relevant to the substance of the petition.

An investigation begins upon a written application by or on behalf of the domestic industry, which includes:

• sufficient evidence of dumping or subsidisation;
• injury under Article VI of GATT 1994; and
• a causal link between the subsidised or dumped imports and the injury.

Authorities must, however, verify the evidence before initiating. Investigations should conclude within one year, and no later than 18 months, unless exceptional circumstances arise. Anti-dumping duties are imposed when dumped imports cause material injury to a domestic industry producing a like or competing product. Countervailing duties apply when specific subsidies lead to such injury.

The GITC is required to publish the report of its finding in the Gazette, in a daily newspaper of nationwide circulation, and on the website of the GITC.

GITC cannot unilaterally impose AD/CVD or safeguard duties on imports from:

• other ECOWAS member states without approval from the ECOWAS Commission under the ECOWAS Trade Liberalisation Scheme;
• AfCFTA member states unless in accordance with specific rules of the AfCFTA such as Annex 9 of the AfCFTA Protocol on Trade in Goods;
• WTO member states unless in accordance with due process under the WTO rules, and notifying the WTO Committees on Anti-Dumping, Subsidies or Safeguards; and
• EU member states.

AD/CVD duties and safeguards must be reviewed at least once every five years or when there is a significant change in circumstance.

The GITC review process starts when an interested party submits an application or the GITC initiates a review. Applications must demonstrate either significant changes in market conditions, or a risk that dumping/subsidisation and injury would recur. If the evidence is sufficient, the GITC issues a Notice of Initiation in the Gazette and a national newspaper, specifying the following:

• nature of the review;
• product;
• countries/exporters;
• period under review; and
• submission deadlines.

Questionnaires are sent to exporters, importers and domestic producers, and the parties must respond within 30 to 45 days, with all submissions subject to confidentiality rules. The GITC verifies data, including costs, pricing, export sales and production. Interim reviews assess material changes, and sunset reviews evaluate the likelihood of continued dumping or injury. A preliminary report may be issued for comments from interested parties.

The Final Report does the following:

• states the facts;
• addresses comments; and
• specifies whether measures will be maintained, varied or terminated.

The decision is published in the Gazette and a national newspaper, and communicated to the Minister responsible for Trade. The entire review process should not exceed 12 months.

An appeal of such duties is by way of judicial review by the High Court, within six months from the date of the decision.

There are no notable developments in the past 12 months related to trade remedies.

There is increasing pressure for authorities to adopt more transparent practices in trade remedy investigations. Thus, WTO Committees in their periodic reviews of notifications may push members to enhance compliance in transparency and procedure. There will be the need for better publication of data, digital submission systems and clearer procedural timelines.

The primary regulatory body is the Securities and Exchange Commission (SEC) established under the Securities Industry Act (Act 929), which regulates investment-securities markets and investment schemes. The Ghana Investment Promotion Centre (GIPC) Act (Act 865) also governs foreign investment registration, incentives and investor protection. The Ghana Free Zones Authority, under the Free Zones Act (Act 504), oversees special export-oriented investment zones with enhanced protections and security mechanisms. Companies with foreign participation must register with the GIPC, and access incentives and protections following registration.

As part of investment security, companies with foreign ownership must register with the GIPC after incorporation, which provides a certificate and access to protections/incentives. The review process includes:

• submission of incorporation documents;
• verification by the GIPC; and
• issuance of an investment certificate.

Once registered, the investor benefits from dispute-resolution support and protection under the relevant statutes.

Revisions to the investment regime – for instance, the possible revision of minimum foreign-capital requirements as announced recently – indicate potential changes in the securities and regulatory environment. While exact timelines for review vary by project and sector, registration with the GIPC is a prerequisite for accessing security protections and incentives; delays may arise in verification or approvals. Oversight by the SEC, on the other hand, applies to investment schemes, with monitoring, registration and enforcement to protect investors against misrepresentation.

The relevant government agencies include the GIPC and SEC.

In Ghana, a transaction becomes subject to investment security measures or review when it involves activities that could affect national interest, financial stability or investor protection, typically under the oversight of the SEC, GIPC, Bank of Ghana (BoG) or related agencies.

As discussed above, in Ghana, the GIPC Act requires that companies with foreign participation must register with the GIPC before commencing operations. Enterprises with foreign participation must renew their registration every two years.

Under the Companies Act, 2019 (Act 992), every company must register with the Registrar of Companies before starting business. Sections 13 to 15 require submission of company details, including:

• name;
• business type;
• registered office; and
• particulars of directors, shareholders, auditors and the secretary.

Act 992 also introduces a beneficial ownership disclosure regime. Section 13(2)(m) mandates disclosure of beneficial owners at registration, while Sections 35 and 36 require maintaining an up-to-date register and notifying the Registrar of changes within 28 days.

Sections 373, 378 and 379 empower the Registrar to:

• issue regulations;
• demand information;
• inspect records; and
• impose sanctions for non-compliance.

This promotes transparency, supports AML efforts and strengthens investment security oversight.

Certain public bodies and state-owned enterprises (SOEs) engaging in commercial activities under statutory authority are not required to undergo GIPC investment registration or approval. Their activities are governed by the enabling statutes or by specific ministerial or cabinet oversight rather than investment security screening. Nonetheless, investments or partnerships involving foreign entities in strategic sectors such as energy, mining, telecommunications and financial services remain subject to review and approval by relevant regulators such as the Ministry of Energy, Minerals Commission, National Communications Authority, and the Bank of Ghana.

In effect, while Ghana’s framework provides no express “exemption list”, purely domestic investments and certain statutory entities operate outside the GIPC’s investment security review mandate.

GIPC Act

Under Section 40, failing to register or renew registration, engaging in unapproved activities or misusing benefits constitutes an offence. Penalties include a fine of 500 to 1,000 penalty units, with an additional 25 to 50 units per day for continuing offences. The GIPC may also:

• suspend or cancel registration;
• revoke incentives;
• order payment of fees, taxes and duties; or
• advise the Bank of Ghana to suspend capital, profit or dividend transfers.

Companies Act

The following provisions impose penalties.

• Section 344 – Making untrue, misleading or deceptive statements or promises to induce another person to enter into agreements involving securities, lending, deposits or profit from securities fluctuations is an offence. Offenders face three to seven years’ imprisonment unless they can show reasonable belief in the statement’s truth. Concealing material facts to induce such transactions carries the same penalty.
• Section 345 – Wilfully submitting false statements in returns, reports, certificates, accounts or other documents to the Registrar, knowing them to be false, is punishable by 250 to 500 penalty units, one to two years’ imprisonment, or both.
• Section 347 – Companies must publish accurate information on authorised or issued shares and stated and paid-up capital in any notice, advertisement, business letter or publication. Failure to comply exposes both the body corporate and responsible officers to an administrative penalty of 750 penalty units.

In Ghana, there are generally no standalone “investment security review” fees in the same sense as foreign investment screening regimes in countries like the UK or the US. However, certain regulatory filings, approvals and licensing steps connected to investment security, particularly under the SEC, GIPC and BoG, do attract statutory fees.

In July 2025, the SEC warned that some news platforms were promoting unlicensed schemes, including “Gold AI Rise Platform”, not licensed under the Securities Industry Act. The SEC also published and maintains a list of “entities operating without a licence” on its website, as part of its investor-protection mandate.

In August 2025, the SEC announced a collaboration with the Ghana Journalists Association (GJA) and other bodies (such as the Cybersecurity Authority and the Ghana Police Service) to tackle promotion of unlicensed investment schemes, particularly those leveraging social media, AI and other technologies. The SEC issued Guidelines on Dealing in Government of Ghana Securities 2025 (SEC/GUI/001/07/2025) for licensed dealers and brokers.

Growing media coverage of unlicensed platforms highlights investor risks, reputational exposure for intermediaries, and potential legal liability for promoters or advisers, emphasising the need for investor awareness and compliance.

The SEC has issued a batch of 2025 guidelines (including Financial Resources and Government-Securities guidelines) that raise minimum capital, liquidity and reporting requirements for licensed market operators and place a greater compliance burden on broker-dealers, primary dealers, funds and other intermediaries.

The Bank of Ghana, in collaboration with the SEC and the Financial Intelligence Centre, is introducing a comprehensive legal framework to regulate Virtual Asset Service Providers (VASPs) in Ghana. The initiative aims to:

• safeguard financial stability;
• protect consumers and investors; and
• enhance compliance with Anti-Money Laundering, Counter-Terrorist Financing, and Proliferation Financing standards.

It also seeks to:

• foster responsible innovation in the financial sector;
• strengthen domestic co-ordination in managing risks associated with virtual assets;
• promote international co-operation in combating financial crime; and
• address cybersecurity threats linked to virtual asset operations.

The proposed Virtual Asset Service Providers Act, 2025, once it enters into force, will provide the legal foundation for the registration, licensing and supervision of VASPs in Ghana.

Ghana uses a number of incentives and subsidy schemes to encourage homegrown manufacturing and lower imports as highlighted below.

• Under the Ghana Investment Promotion Centre Act, 2013 (Act 865), the Ghana Investment Promotion Centre (GIPC) provides a range of investment incentives to enterprises engaged in manufacturing and value addition.
• The government has introduced Special Economic Zones (SEZs) and Industrial Parks, notably the Tema Export Processing Zone (EPZ), offering corporate tax exemptions, customs duty waivers and repatriation incentives to manufacturing enterprises producing primarily for export or local substitution. Complementary initiatives such as the Ghana Automotive Development Policy and Ghana Integrated Aluminum and Iron and Steel Development Initiatives also provide targeted tax incentives and infrastructure support to encourage local assembly, processing, and value addition to raw materials.

Ghana applies technical and regulatory standards to safeguard product quality, protect consumers and support domestic industry. These measures, implemented mainly by the Ghana Standards Authority (GSA), Food and Drugs Authority (FDA), and sectoral regulators, serve both public safety and industrial policy objectives.

Ghana Standards Authority (GSA)

Under the Ghana Standards Authority Act, 2022 (Act 1078), the GSA develops, adopts and enforces national standards for all goods, local or imported. Through its Conformity Assessment and Product Certification Scheme, particularly the Ghana Conformity Assessment Programme (G-CAP), regulated imports must obtain a Certificate of Conformity before shipment. This ensures imported goods meet Ghanaian standards, curbing substandard imports and supporting fair competition for local producers.

Sectoral Regulatory Measures

Regulators such as the FDA and Energy Commission apply complementary standards that reinforce industrial policy goals. The FDA, under the Public Health Act, 2012 (Act 851), approves only food, cosmetics and pharmaceuticals that meet national quality standards. The Energy Commission enforces Minimum Energy Performance Standards (MEPS) and appliance labelling rules to bar inefficient imports and encourage local assembly of compliant products. Collectively, these frameworks promote consumer safety and domestic industrial growth.

Ghana enforces Sanitary and Phytosanitary (SPS) measures under the following:

• Plants and Fertilizers Act, 2010 (Act 803);
• Public Health Act, 2012 (Act 851); and
• regulations of the FDA and Veterinary Services Directorate.

Imports of food, livestock and plant materials must meet strict inspection, certification and quarantine standards to prevent pests, diseases and contamination. The GSA also sets safety benchmarks for imports. These SPS controls safeguard public health, ensure quality, and protect local farmers and processors from unfair competition, thereby reducing unsafe imports and encouraging domestic production.

The Protection Against Unfair Competition Act, 2000 (Act 589) prohibits anti-competitive import pricing. Public entities such as the National Petroleum Authority (NPA) regulate prices of essential goods and services to stabilise domestic costs. Also, the Ghana International Trade Commission (GITC) Act, 2016 (Act 926) empowers government to impose anti-dumping and safeguard duties on cheap imports, thereby encouraging domestic production and maintaining industrial competitiveness.

The State Interests and Governance Authority (SIGA)

The State Interests and Governance Authority Act, 2019 (Act 990) established SIGA, which serves as the central oversight body for state-owned enterprises (SOEs), joint venture companies, and other state entities (“Specified Entities”). Section 3(e)(i) empowers SIGA to ensure that these entities implement measures promoting socio-economic growth across agriculture, industry and services, guiding SOEs to support national industrial and economic development and policies favouring local production over import dependence.

State Trading and Market Control

Ghana National Petroleum Corporation (GNPC) operates as a state trading entity in petroleum under the GNPC Act, 1983 (PNDCL 64), managing exploration, development, production and disposal of petroleum while retaining domestic value.

Ghana National Gas Company (GNGC), fully government-owned under the Incorporation Instrument 2011 (EI 17), gathers, processes, transports and markets natural gas domestically to support local industry and power generation.

Public-Private Partnership (PPP) Framework

Under the Public-Private Partnership Act, 2020 (Act 1039), Section 1 promotes local participation in PPP projects, while Section 10 ensures projects facilitate local content, technology transfer, and the development of local industries and private sector.

Margin of Preference for Local Goods and Services

Under Sections 59(3b) and 60 of the Public Procurement Act, 2003 (Act 663) as amended by Act 914, entities engaged in procurement must grant a margin of preference to domestic suppliers, contractors or locally produced goods when evaluating tenders. Such preferences are subject to authorisation and approval by the Public Procurement Board, promoting competitiveness of Ghanaian products and services.

Restriction of Participation

Section 44 of Act 914 permits procurement entities to restrict national competitive tendering to only Ghanaian suppliers, contractors or consultants. This provision operationalises “Buy National” requirements, encouraging local participation and strengthening domestic industry capacity.

Sectoral Local Procurement Requirements

Local content regulations in key sectors reinforce “buy local” mandates: LI 2354 (Electricity Supply Industry), LI 2431 (Mining) and LI 2204 (Petroleum) compel companies to source goods, services and labour locally. These measures foster industrial development, enhance Ghanaian participation, and build domestic supply chains across strategic industries.

Government’s “Made in Ghana” Policy (2024 to 2025)

Current policy initiatives by the Ministry of Finance and PPA aim to entrench a “buy national” approach through a forthcoming Made-in-Ghana Procurement List and a requirement for presidential approval before importing goods available locally. This policy seeks to cut import dependence, stimulate domestic manufacturing, and ensure sustained demand for Ghanaian-made products in public procurement.

Ghana protects its geographical indication (GI) under the Geographical Indications Act, 2003 (Act 659). While Ghana’s geographical indication protection system is not explicitly designed as an import restriction tool, it serves as an indirect trade and industrial policy measure by doing the following.

• Enhancing market value – The regime achieves this through its registration and exclusivity framework. Under Section 11, only producers operating within the designated area may use a registered GI for goods possessing the specified quality or reputation. Section 10 permits GI registration, allowing producers to differentiate their goods by origin and quality, thereby enhancing market value.
• Encouraging origin-based production – Though not stated explicitly, Sections 6 and 7 enable producers within a defined geographical area to apply for a GI, detailing the goods, area and qualities linked to origin. This structure incentivises production of goods whose distinct characteristics stem from their place of origin.
• Protecting local producers from unfair competition – Section 1 authorises civil action to prevent misleading indications of origin, while Section 5 criminalises such acts and related unfair competition under Act 589. These provisions safeguard legitimate local producers against deceptive imports or substitutes.
• Promoting exports of authentic Ghanaian goods – Though exports are not directly mentioned, Sections 2 and 22 ensure protection and recognition of GIs as identifiers of authentic origin-linked goods. This strengthens the credibility and export potential of genuine Ghanaian products.

There are no further significant issues or developments to be discussed.