The Bank of Ghana has ordered commercial banks to halt foreign currency cash payments to large corporates unless those payments are fully backed by equivalent foreign currency cash deposits, escalating the central bank's campaign to enforce the country's foreign exchange laws. Notice No. BG/GOV/SEC/2025/26, issued on 27 August 2025, singles out bulk oil distributors and mining firms as the primary categories of large corporate recipients affected by the directive, and makes clear that non-compliance will attract regulatory sanctions.
The notice reinforces a long-standing statutory position under Ghanaian law: the Ghana Cedi is the sole legal tender, and pricing, advertising, or invoicing goods and services in a foreign currency is prohibited under the Foreign Exchange Act. The Bank of Ghana's directive builds on what the central bank describes as its tightened sanctions regime for foreign exchange violations throughout 2025, extending its enforcement reach into the specific area of FCY cash disbursements to large corporates that are not matched by identifiable deposit backing.
DOCUMENTATION REQUIREMENTS FOR FCY PAYOUTS
Beyond the prohibition on unfunded disbursements, the directive places explicit record-keeping obligations on banks. Each institution is required to maintain documentation that verifies the source of funds for every foreign currency payout it processes. This paper trail requirement is designed to give supervisors a clear audit path and to close off informal workarounds by which FCY cash has previously been channelled to large corporates without transparent funding backing. Banks that cannot produce the required documentation upon supervisory request will face the same sanctions risk as those that fail to enforce the deposit-matching requirement itself.
The practical effect on the affected sectors is immediate and significant. Bulk oil distributors, which depend heavily on foreign currency transactions to settle import obligations for refined petroleum products, and mining companies, whose contracts are typically denominated in US dollars or other hard currencies, will now be required to demonstrate that any FCY cash they receive from the banking system corresponds precisely to deposits of equivalent value already held at the disbursing bank. This creates an additional layer of pre-disbursement compliance that banks must embed in their treasury and trade finance workflows without delay.
CONTEXT: TIGHTENED FX ENFORCEMENT IN 2025
The directive is part of a wider pattern of regulatory tightening by the Bank of Ghana this year. The central bank has progressively strengthened its sanctions framework for foreign exchange infractions, and Notice No. BG/GOV/SEC/2025/26 builds directly on that trajectory. By requiring banks to act as the primary compliance gatekeepers for FCY cash flows to large corporates, the Bank of Ghana is distributing supervisory responsibility across the banking sector rather than relying solely on its own inspection capacity. The approach effectively turns individual banks into the first line of enforcement for the Foreign Exchange Act in the corporate FCY disbursements segment.
For the Ghanaian banking sector, the notice demands prompt adjustments to internal controls and compliance procedures, particularly in treasury and trade finance departments that handle high-volume FCY transactions for commodity sector clients. Banks that have not already established robust source-of-funds verification processes for outbound foreign currency payments will need to act quickly. The Bank of Ghana's warning that sanctions will follow non-compliance leaves institutions with limited room to treat the directive as guidance rather than a binding requirement, and compliance officers will be expected to update their institutions' FCY payment procedures to reflect the new obligations set out in Notice No. BG/GOV/SEC/2025/26.