I chaired the Inter-Ministerial Committee on Illegal Mining from March 2017 until January 2021.
The rivers I was appointed to protect are in a worse state today than when I took office. I begin there because no account of that work is worth reading if it begins anywhere else.
Richard Dablah’s essay deserves a serious answer, and I want to give it one. He is right that the young man in the pit is not the beginning of galamsey but its most expendable participant.
He is right that before gold reaches his hands, someone has financed the operation, supplied the machinery, facilitated access to land, arranged the processing, moved the money and, often enough, provided the protection.
He is right that this makes galamsey a network rather than an activity, and that networks are not dismantled by repeatedly arresting their lowest-ranking members.
He is right, above all, about the accounting. Illegal mining transfers value from the future to the present.
The miner takes today’s income, the financier today’s return, and the trader today’s margin, and society inherits tomorrow’s bill in contaminated water, ruined farmland, and lost forest and public health costs that no one has ever priced.
I would add only that the bill is no longer in the future. Ghana had about 8.8 million hectares of primary forest at the turn of the last century, 4.2 million by 1950, and roughly 1.5 million by 1999. We are paying now.
Where I must part company with the essay is on one factual premise that runs beneath the whole argument: that Ghana has never attempted the intelligent version of this fight, and that what is needed is an “ecological intelligence system” satellite imagery, drones, geospatial linkage of licences to forests and rivers, equipment registration, financial intelligence, gold traceability, that the country has yet to imagine.
Ghana imagined it. Ghana built most of it. That it is unknown to a careful writer on the subject is not his failure but the state’s, and I will come to that.
What was built
Between 2017 and 2019 the committee I chaired put in place, with the stakeholder agencies, very nearly the architecture Mr Dablah describes.
Every artisanal and small-scale mining concession in the country was surveyed and mapped using global navigation satellite systems and drone technology so that for the first time the state held a verified baseline of where each licence physically sat on the ground.
Of some five thousand entities written to, one thousand three hundred and fifty appeared, were vetted against their licences, permits, tax identification, and company registration, and were regularised.
They were issued digital identity cards carrying Ghana Post GPS codes and licence validity, and signposts were erected at their concessions declaring ownership and boundaries.
The names were published in the newspapers and on radio. Four thousand miners were trained in sustainable mining and mineral processing at the University of Mines and Technology at Tarkwa, at the state’s expense.
Underneath all of this sat GalamSTOP. It was not, as is still sometimes reported, a task force. It was a software platform: a web application with full geographic information system capability, an Android application with custom GPS for field officers, a reporting dashboard, a data management system, and an online application and payment system.
It managed the entire lifecycle of a mining right from application through licensing and renewal to expiry. Its compliance module tracked payments made and outstanding, royalties, production reports, and contract terms.
It was designed from the outset to integrate the Environmental Protection Agency, the Water Resources Commission, the Forestry Commission, the Driver and Vehicle Licensing Authority, the Minerals Commission, and the district assemblies onto a single view so that the state could ask, in something close to real time, exactly the questions Mr. Dablah poses: where is the excavation, who holds the licence, whose machine is that, and is this inside a protected area?
We used satellite imagery as a matter of routine. The progressive destruction of the Apaprama and Kobro forest reserves and the diversion of the River Offin were documented in a time series of images running from December 2017 to the middle of 2020.
On the rivers, we stopped burning the engines of dredging platforms; the miners bought new engines within a day, and instead partnered with a trained diving and salvage outfit to tow the entire rigs away to depots far from the water. The miners lost everything. That worked.
What happened to it
The Forestry Commission refused to migrate onto the platform. The Minerals Commission approached it half-heartedly. That is the sentence I would ask readers to sit with, because it explains more about galamsey than any description of a pit.
There is a second sentence of the same kind. On 28 February 2019 Cabinet, having received an update on the committee’s work, directed the Minister for Lands and Natural Resources to suspend the issuance of all new prospecting licences by the Forestry and Minerals Commissions, and to suspend the licences already issued for operations in forty-seven forest reserves, pending environmental impact assessment. The directive was conveyed in writing on 4 March 2019.
It was not carried out. The destruction continued.
A monitoring platform is an instrument of visibility, and an agency that does not wish to be seen will decline to be instrumented.
A written directive from the Cabinet is an instrument of authority, and authority that is not enforced upon those who ignore it is advice.
This is what I would offer Mr Dablah’s argument as its missing variable. Every technology on his list is real, available and useful. None of them fails at the point of capability.
They fail at the point of institutional adoption, at the moment when an agency, a ministry or a well-connected licence holder must consent to be observed, measured and, if necessary, acted against. A design that does not solve for adoption is not a system. It is a wish.
Where he is ahead of us
I do not want to answer a good essay only by claiming precedence, because on three matters he is ahead of what we built, and I should say so plainly.
First, monetisation. Our architecture was strong at the site and nearly silent on how illegal gold becomes legitimate money.
Traceability from mine of origin, due diligence on aggregators and refiners, controls at the point of export, and financial investigation that follows wealth upward rather than stopping at the man in the pit, none of that was built, and much of it lay outside the mandate of the Ministry I held.
He is right that making illegally produced gold difficult to monetise is a more strategic objective than making illegal mining physically difficult.
Second, ecological accounting. We calculate gold production, export earnings and foreign exchange to the last decimal. We have no national account that carries a destroyed watershed as a liability.
Until environmental depletion appears on the national balance sheet as a real economic cost, extraction will go on masquerading as wealth creation. That is his phrase and it is exactly right.
Third, benefit-sharing. We ran alternative livelihood programmes and I still believe in them, but vocational training is not the same thing as a genuine stake in the mineral wealth beneath a community’s own land.
He is right that the supply of recruits is an economic fact before it is a criminal one and that no amount of policing removes an economic fact.
Why this matters now
These are not academic points in 2026. The Ghana Gold Board is currently tendering for a blockchain-based track-and-trace system, intended for deployment by the end of this year, to tie every gram of gold it buys to a verified mine of origin.
L.I. 2462, which permitted mining in forest reserves, has been revoked. Restrictions on excavator importation and the tracking of excavators have been reintroduced the same measures directed in the third quarter of 2018, which were never enforced.
And the Forestry Commission has itself now published a satellite-based assessment finding that 8,923.8 hectares across forty-five forest reserves and a national park had been damaged as at the end of 2024, using precisely the method it declined to adopt when it was offered to it.
I welcome every one of these developments without qualification, and I have no interest in whose administration introduced them. But I have watched this film before, and I know how it ends when the last reel is missing.
A traceability system is only as good as the institutions willing to be bound by it. If licensed operators can wash tainted gold through their own permits for a fee, the register will simply record laundered provenance with greater precision than before. The instrument will be excellent. The outcome will be identical.
A word about the record
Mr Dablah could not have known most of what I have set out here, and that is not his fault. GalamSTOP was never publicly documented in any accessible form. No public account of the committee’s methods was ever published by the state.
What the country knows of that work it knows because a report I wrote in March 2021 for internal purposes found its way into the newspapers two years later, and was then read as a catalogue of accusations rather than as a record of an architecture.
A state that does not publish its own institutional memory should not be surprised when its citizens propose, in good faith, that it build what it has already built and abandoned. If nothing else comes of this exchange, I would like that to change.
The question, restated
Mr Dablah ends by asking how Ghana redesigns a national system in which destroying a river can be profitable, politically survivable, and economically rational. It is the right question, and I would restate it only slightly, in the light of four years spent inside the attempt.
The technology is not the constraint. The law is largely not the constraint. The constraint is whether the institutions charged with enforcement can be made independent enough, and durable enough to act against the people they will inevitably be required to act against including those who appointed them. Everything else follows from that, and nothing works without it.
The river, as he writes, has no political constituency. It cannot finance a campaign, threaten an election, or hire lawyers.
Institutions exist precisely to be the constituency of the things that cannot speak for themselves. That is the whole of their justification. Ours were captured by the things that can.
