Governance think tank, Africa Policy Lens (APL) has triggered the Right to Information (RTI) Act, submitting a detailed 20-question request to the Bank of Ghana (BoG) seeking full disclosure on the central bank’s recent divestment of gold reserves.
The petition, filed, demands granular data on the sale of approximately 22 tonnes of gold between September and December 2025, a move the BoG previously described as “strategic portfolio rebalancing” but which has since sparked intense public debate regarding market timing and potential revenue losses.
“The primary objective of this RTI request is to ensure that the management of our national gold reserves is conducted with the highest levels of transparency and fiduciary responsibility. We believe the public deserves to know the exact terms under which these strategic assets were liquidated, especially given the subsequent record-breaking rally in global gold prices.”
Africa Policy Lens (APL)

The APL’s inquiry centers on the operational specifics of the divestment, including the identities of the counterparties involved, the specific dates of each transaction, and the exact price points at which the bullion was liquidated.
This request follows a volatile period where global gold prices surged to record highs, leading critics to suggest that the central bank’s decision to halve its gold exposure from 38 tonnes to roughly 18.6 tonnes may have cost the state hundreds of millions of dollars in unrealized gains.
As a leading voice in mining and extractive advocacy, APL is leveraging the RTI framework to transition the discourse from “speculative claims” to a fact-based assessment of the bank’s fiduciary performance.
According to Africa Policy Lens (APL), “demand for answers is not merely a call for data, but a push for institutional accountability in the governance of Ghana’s extractive wealth.”
Assessing the Cost of “Portfolio Rebalancing”

The essence of APL’s request lies in the inherent public interest attached to the nation’s “strategic anchor” assets.
By demanding a line-by-line breakdown of the transactions, APL aims to determine if the BoG adhered to “international best practice on concentration risk management” as claimed, or if the timing was, as some critics suggest, “catastrophic.”
Through this intervention, the think tank seeks to establish a precedent where significant shifts in national reserve composition are backed by documented, justifiable economic rationales rather than opaque administrative decisions.
The controversy has deepened as market analysts point to the divergence between the BoG’s liquidation window and the subsequent “unprecedented gold price rally.”
Governor Dr. Johnson Asiama had previously defended the move, stating the bank “converted the bullion into foreign exchange” to achieve a 20% target allocation, yet APL argues that “strategic diversification” should not occur at the expense of “market-savvy timing.”
The 20-question probe specifically asks whether the BoG utilized “hedging strategies” to protect the value of the reserves during the transition or if the state was left exposed to the “opportunity cost of rising prices.”
Strengthening Institutional Accountability

BoG’s response or lack thereof will serve as a litmus test for the effectiveness of Ghana’s transparency laws within the financial and extractive sectors.
A comprehensive disclosure would significantly “strengthen transparency and accountability” by allowing independent analysts to verify the central bank’s claim that the proceeds remain “fully within Ghana’s international reserves” and are “actively invested to support reserve accumulation.”
Such clarity is crucial to restoring public confidence, particularly as the newly established Ghana Gold Board (GoldBod) assumes a more central role in the nation’s gold acquisition strategy under the 2025 Ghana Gold Board Act.
This move by APL aligns with global standards such as the Extractive Industries Transparency Initiative (EITI), which emphasizes the “social licence to operate” through the open disclosure of mineral revenues.
As Ghana navigates its Ghana Accelerated National Reserve Accumulation Policy (GANRAP), the APL’s 20-question probe ensures that “good governance and value retention” are more than just policy rhetoric.
By holding the central bank to the light, APL is reinforcing the idea that the nation’s mineral wealth must be managed with a level of openness that leaves no room for “informational asymmetries.”
Navigating the Future of Reserve Management

Ultimately, the resolution of this RTI request could redefine the relationship between state financial institutions and the citizens they serve.
If the Bank of Ghana provides the requested details, it will validate the bank’s commitment to an “informed view of global gold price trends” and prove that its “approach is not speculative.” Conversely, continued opacity would only fuel calls for a “bipartisan parliamentary investigation” into the transaction.
For the mining and extractive sector, the outcome of this APL-BoG standoff will determine whether Ghana’s gold remains a source of national stability or a flashpoint for governance disputes.
The timing of this request is also pivotal as Parliament recently passed GANRAP, which now includes a requirement that any “future sale of accumulated gold reserves” must receive prior parliamentary approval. APL’s action essentially seeks to apply this standard of oversight retrospectively to the late-2025 sales.
By demanding answers now, the think tank is ensuring that the “lessons from the 22-tonne divestment” are integrated into the legislative and operational framework of the Ghana Gold Board, preventing what many fear could be a “pattern of suboptimal asset management.”
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