The Ghana Association of Banks (GAB) has moved swiftly to dispel growing public concern over alleged irregularities in the use of Import Declaration Forms (IDFs).
The Association insists that commercial banks neither issue nor control the document.
The Association says the IDF, which has recently become the subject of public debate, is strictly a customs instrument managed by the Ghana Revenue Authority (GRA) through its Integrated Customs Management System (ICUMS).
In a strongly worded clarification, the GAB said banks only facilitate legitimate trade payments within the regulatory framework set by the Bank of Ghana (BoG) and the GRA. “Banks have no role in the creation or issuance of IDFs.
Their role is limited to facilitating legitimate trade payments for importers,” the statement emphasised.
Importers exploiting loopholes
The Association, however, admitted that its members have observed worrying practices among some importers who exploit weaknesses in the IDF process.
According to the GAB, certain importers initiate advance payments using an IDF obtained for a legitimate import transaction, but later generate new IDFs when the goods arrive — often in a bid to under-invoice and evade customs duties.
“These activities occur outside the banking system’s visibility and oversight,” the statement explained, adding that banks become aware only when inconsistencies appear between initial payments and subsequent documentation.
When such incidents are detected, the affected banks suspend further advance payments to those customers until the original documentation is verified.
Yet, the GAB noted that some importers, particularly those with accounts in multiple banks, exploit the lack of centralised visibility in the financial system to continue such practices elsewhere.
“This highlights a broader system-wide loophole that extends beyond any single bank,” the Association lamented.
Banks, regulators move to close loopholes
To address these systemic risks, the GAB said it has initiated a multi-stakeholder consultative process involving the Bank of Ghana, the Ghana Revenue Authority, ICUMS, and member banks.
The committee, formed at the instance of the Association, was tasked with reviewing the IDF framework, identifying gaps, and developing coordinated solutions to enhance oversight and prevent abuse.
“Each stakeholder was assigned specific responsibilities,” the GAB noted.
“The Bank of Ghana and the banks have substantially completed their respective tasks, while further engagements with the GRA and ICUMS are ongoing to ensure the complete closure of identified loopholes.”
Clarifying the $200,000 rule
The Association also addressed public confusion about a supposed $200,000 transaction limit imposed on importers. It explained that the limit only applies to customers who do not have complete import documentation at the time of requesting payment.
“Customers who possess full and verified import documentation are not subject to this limit and may process legitimate payments exceeding that amount — including transactions of several million dollars — in line with regulatory provisions,” the statement clarified.
Banks reaffirm compliance and integrity
The Ghana Association of Banks reiterated that its members operate under strict compliance regimes and maintain robust internal controls to ensure all foreign exchange and trade transactions conform to regulatory and prudential standards.
“The alleged irregularities do not stem from the actions of banks but from systemic misuse of IDFs by certain importers,” the statement stressed.
The GAB reaffirmed its commitment to transparency, regulatory compliance, and ethical banking practices that safeguard confidence in Ghana’s financial system and uphold the integrity of international trade operations.