For all the years Ghana has battled illegal mining — or ‘galamsey’, as we call it — the missing piece has never been social passion or political will. It has been clarity. Clarity of purpose, clarity of structure, and clarity of method. Without clarity, every good policy ends up chasing its own tail.
If we could build this clarity into our gold policy, the ‘galamsey’ problem would lose its sting within eighteen months. One thing is certain: Ghana doesn’t need to end small-scale mining; it needs to fix it. By fixing it, we don’t mean simply licensing miners. The goal should be to transform illegal artisanal and small-scale gold mining (ASGM) operations into legal, well-regulated, and environmentally responsible enterprises that meet recognised environmental, social and governance (ESG) standards.
At present, only three out of every twenty ASGM operations in Ghana meet standard ESG requirements. That’s not because miners are inherently lawless, but because the system they are expected to operate under was designed for a different world. It is a system that treats local miners as though they were multinational corporations, requiring them to jump through the same bureaucratic hoops before they can legally operate.
Yet this same small-scale mining industry is too important to marginalise. It supports more than four million Ghanaians directly and indirectly — this translates to one in every ten Ghanaian citizens. The sector contributes close to 60 percent of Ghana’s total gold exports, with an estimated value of nearly a billion dollars a month. Clearly, it’s not a problem to be eliminated, but an industry to be reorganised and optimised for sustainability.
The current overall approach, however, appears to be counterproductive. At the moment, all mining activities begin with a reconnaissance license, followed by an exploration license, and finally a mining license. In theory, this sequence ensures proper geological assessment before extraction. In practice, it creates hurdles too steep for small-scale operators who lack the sophistication and funding to conduct such preliminary studies.
And even when mining licenses are finally granted, they are too broad in scope. The same small-scale mining license allows holders to extract ore and process ore. This dual permission stretches the regulator’s capacity for proper monitoring beyond its limit. Typically, extracting ore and processing ore are bunched together under mining. But in essence, they are two distinct steps in the gold value chain.
Mining comprises getting gold ore out of the ground and then processing it to get doré out of the ore. It would be prudent to decouple the two activities to optimise operational efficiency and regulatory compliance. With thousands of miners scattered across the country, it is impossible for the state to effectively monitor both mining and processing under a single license. The outcome is predictable: poor oversight, weak compliance, and widespread environmental destruction.
You might find it interesting to know that the real problems ‘galamsey’ is notorious for lie not in the extraction, but in the processing. It is at the ore processing stage that mercury, cyanide, and other harmful chemicals find their way into the rivers and the soil. Most illegal operations mess up the environment not because they extract irresponsibly, but because they process irresponsibly. Ore processing is, therefore, where policy reform is most essential.
A more efficient ASGM policy model would separate mining from processing under two distinct licenses. The mining license should cover only drilling, blasting, excavation, and ore extraction. Processing should be reserved for operators holding a newly instituted Gold Processing License, issued specifically for the construction and operation of ESG-compliant industrial gold processing mills. More importantly, mill owners should be allowed to process ore on behalf of third parties, ie, miners, without having to operate mines themselves.
Under this system, dedicated industrial processing operators would set up standardised gold ore processing mills in ASGM hubs across the country. Small-scale miners would simply deliver their ore to these mills for processing into doré. Each mill would operate under strict ESG standards and be designed according to state-approved models. This change alone would transform oversight: regulators would know exactly where processing happens, and at what scale, making it easier to enforce safety and environmental rules.
At first glance, the new framework may seem to disadvantage miners, who would now have to send their ore to third-party industrial mills before obtaining their gold doré to sell. Under the current setup, small-scale miners handle both extraction and processing themselves, appearing to maintain some level of vertical integration. This scope of operations should instead be reserved for a different mining category – Medium-scale Mining (MSM).
In reality, this change could prove beneficial for miners. By allowing them to focus solely on extracting high-grade ore from their mines, the process becomes more efficient. Industrial mills, with their advanced equipment and higher output, can process ore faster and at a greater scale than individual miners could ever manage on their own.
This separation of roles—miners extracting and mills processing—would lead to higher recovery rates and reduce the environmental harm caused by sub-standard on-site methods. It would also enable miners to channel their time and capital into the core business of mining rather than splitting resources between mining and processing.
When most Ghanaians think of small-scale mining, they picture miners working with shovels, pickaxes, and pans. These are rightly called artisanal miners. They typically run low-volume, labour-intensive operations. Because they extract such limited quantities, artisanal miners would gain little from using industrial mills. They should therefore be allowed to process their own ore, as their environmental impact, though visible, remains relatively minor. Artisanal mining and small-scale mining, therefore, ought to be more clearly distinguished in policy as well.
The real issue lies with the larger “small-scale” miners who operate with excavators, tipper trucks, and heavy machinery. Though licensed as small-scale, their footprint and output resemble mid-tier operations. These are the groups whose inefficient processing methods cause widespread pollution and land degradation.
It is for such miners that we propose, their processing activities should be handled by licensed ESG-compliant industrial gold processing mills. This would improve metal recovery, ensure responsible processing practices, and bring Ghana’s small-scale mining sector closer to international environmental and governance standards.
The Minerals Commission (MinComm) could take the lead by developing standard model mills of varying processing capacities. Each processing license would come with a corresponding model suited to the licensee’s scale of operations. Mills would be constructed according to these approved templates to ensure uniformity, safety, and traceability.
At the same time, innovation should not be stifled. Operators could be allowed to propose alternative mill designs for approval, as long as these designs meet or exceed the state-designated minimum standard. This way, the state sets a regulatory foundation without discouraging private creativity.
This new licensing framework could also be extended upstream. Reconnaissance and exploration licenses should be redefined and issued to third-party service providers who can operate independently and serve multiple clients, ie, mining companies, by providing reconnaissance and exploration services to mining operators.
Reconnaissance licenses and exploration licenses for artisanal miners and small-scale miners in particular should no longer be issued in connection with activity permits on a track of land prior to obtaining a mining lease. In fact, small-scale miners should be allowed to engage in mining without any prior reconnaissance or exploration if they so choose, as long as the scope of the mining lease demands full land reclamation after any mining activities, and proper enforcement measures are put in place.
Typically, mining operators pay processing mills according to the quantity of ore processed, rather than the quantity of doré extracted. The higher the quality of the ore presented for processing, the higher the quantity of doré extracted, which means more profit for the miner. This would inadvertently pressure miners to invest in whatever methods are necessary to ensure that the quality of the ore they tender in at the mills for processing is as high as possible. The need to invest in reconnaissance and exploration services prior to ore extraction would have been created organically.
Such a system would reorganise the entire ASGM value chain into distinct, interdependent segments — reconnaissance, exploration, mining, processing, trading, and export. Each activity would have its own license, its own rules, and its own ESG obligations. This separation would make the industry far easier to monitor. Every ounce of gold could be traced from the concession where it was mined, to the mill where it was processed, to the trader who sold it, and eventually to the exporter who shipped it.
Beyond regulation, this approach makes business sense. It lowers the cost of entry for local players, encourages specialisation, and creates multiple viable business models across the local gold value chain. An operator could run a profitable company focusing solely on processing services or on exploration services. Investors could choose the level at which they want to play— owning mining concessions, offering mining services, operating mills, or financing trade — without having to do everything themselves.
Over time, those who wish to integrate vertically can scale up from one level to another. A small-scale miner could become a medium-scale operator by acquiring new licenses and expanding the scope of their operations. As earlier hinted, if the state adopts a gold policy that recognises medium-scale mining as a distinct category which allows for some level of vertical integration, all the better. The system would not only formalise the sector but also create a clear growth pathway from artisanal mining to a large-scale mining enterprise.
This model also ensures accountability. When each level of operation is separately licensed, regulators can pinpoint responsibility for violations. If a river is polluted, it’s not every miner who’s guilty — it’s the specific processing mill that released mercury into the water. When licenses have clear scopes, enforcement becomes fair and efficient.
It also allows the government to focus enforcement where it matters most. The environmental damage from mining proper — destroyed topsoil, open pits, and deforestation — can be mitigated through strict land reclamation requirements. These are relatively easier to enforce than chasing thousands of illegal mining–plus-processing setups in the bush. When processing is semi-centralised and regulated, most of this chaos disappears. By ‘centralised’, we do not at all imply state-driven. Centralised here refers to a feature of this model that allows several miners within a mining hub to rely on one central industrial ore processing mill. Private sector players can indeed lead the charge.
Once proper ASGM operations become the norm, the age-old argument of ‘galamsey’ being run largely by political kingpins would be moot. As long as these politically active mining kingpins are running ESG-compliant gold operations, it would not be nearly as significant that the gold industry is dominated by politically active persons. After all, the ASGM sector is as legitimate and as valid as any other industry.
Ultimately, Ghana’s ASGM sector doesn’t suffer from a lack of effort. It suffers from a lack of clear direction. Courtesy of the Ghana Gold Board, we see some order within the local gold trading space. We require a similarly cogent strategy for the ASGM space as well, hence the above thoughts. What the country needs is not more bans, state-of-emergencies, or military interventions, but an intuitive system that both reflects and rationalises how the indigenous segment of the local extractive industry actually works.
A clear, well-sequenced licensing regime that separates mining from processing, and opens space for third-party services, would make Ghana’s gold sector cleaner, safer, and more profitable. It would give regulators visibility, investors confidence, and citizens hope.
If the fight against galamsey is to mean anything, it must begin with rethinking the rules that govern the miners themselves. Once the structure is right, discipline will follow naturally. Ghana’s gold will still shine — only this time, without muddying our rivers.
The writer is a global trade & logistics professional. He’s also a self-proclaimed gold industry enthusiast. He explores this industry through the lens of first principles, the basic essentials. Email: mr1stprinciples@gmail.com
