For international fintechs and local payment providers in Ghana, the beginning of September brought a familiar chill. The Bank of Ghana (BoG), in a move that is becoming its signature, published a list. This time, five Money Transfer Operators (MTOs) — including notable names like Taptap Send and Afriex — were handed a one-month suspension from the country’s $4.6 billion remittance market for “unauthorised remittance activities.”
The message was clear, and the method was classic BoG: public, pointed, and punctuated with legal statutes. For the fintech sector, which often thrives on moving fast and (sometimes) breaking things, Ghana’s central bank is the steadfast referee with a zero-tolerance policy for offside plays.
Decoding the New Rulebook
For fintechs scrambling to understand the new landscape, the BoG’s “Updated Guidelines for Inward Remittance Services,” dated August 25, 2025, is now required reading. It’s less a gentle suggestion and more a direct order on how to operate. Here are the key changes designed to trip up the unwary.
1. The “Use It or Lose It” Partner Rule
The regulator has introduced what can only be described as a “dormant partner” clause. Local PSPs must now conduct periodic reviews of their MTO partnerships. Any partnership that shows no transactions for a continuous six-month period is considered dormant, must be terminated, and reported to the Bank of Ghana. This is a direct strike against fintechs accumulating partnerships like digital trophies without generating actual activity, a move aimed at pruning “high-risk operators” who are partners in name only.
2. The End of “Creative” Forex Rates
The BoG is getting pedantic about exchange rates, and for good reason. Previously, settlement banks could use the opening Bloomberg bid rate for converting remittance inflows. The new rule mandates using the Average Opening Bloomberg USDGHS Regional (REGN) bid-ask range. It’s a subtle but critical change. The regulator is squeezing any potential for arbitrage, ensuring that the foreign currency flowing in is converted at a rate that reflects the broader market, not a rate that benefits one party. This move is all about maximising forex value for the country, not for the fintechs.
3. No More Hiding in Plain Sight
Perhaps the most significant technical update is the crackdown on how remittance funds are handled. The BoG now demands that:
- Dedicated Accounts: Funding for remittances must go through a dedicated Online Vendor Account (OVA) used only for inward remittances. Co-mingling funds is officially out.
- Specific APIs: PSPs must develop a remittance-specific API with a unique identifier for each MTO.
- No Misreporting: The guidelines explicitly forbid misreporting remittance inflows as Peer-to-Peer (P2P) transactions.
This is a direct assault on operational shortcuts. The regulator wants total transparency and is forcing providers to build the tech to ensure every dollar is tracked from sender to beneficiary without being disguised as something else along the way.
4. Your Compliance Officer Is About to Get Busier
The reporting cadence has been dramatically accelerated. What was a monthly reporting requirement has now become a weekly report, due every Monday. This shift signals a desire for near-real-time oversight of the market. The days of fixing compliance issues a month after they happen are over. The BoG wants to know what happened last week, now.
5. A Ban on “Preferential Arrangements”
In a new section on “Ethical Business Conduct,” the BoG explicitly prohibits “the payment of rebates, commissions, or preferential arrangements that confer undue advantage or distort market conditions.” This is a shot across the bow of the hyper-competitive MTO industry, where back-end deals to secure exclusive partnerships are common. The regulator is trying to force competition based on service and efficiency, not on who can offer the sweetest under-the-table deal.
A Pattern of Public Enforcement
The suspension of Taptap Send, Afriex, and others is not an isolated event but part of a pattern. The BoG has developed a distinct regulatory style: public enforcement as a primary tool. Recall the case of Yellow Card and its alleged stablecoin scheme, or Eversend being named an unlicensed MTO. The central bank appears to favour public notices over private warnings, using public perception as a force multiplier for its enforcement actions.
The rationale is rooted in cold, hard economics. Remittances are a lifeline for countless Ghanaian families and a critical source of foreign exchange for the nation. The BoG’s primary mandate is stability. Unregulated flows, it argues, pose a risk to monetary policy and can be a conduit for fraud and financial crime. From its perspective, the public naming of offenders is a necessary measure to protect the integrity of the entire system.
The Partner-Led Model’s Single Point of Failure
The recent suspensions highlight the profound risk in the partner-led market entry model favoured by international fintechs. While a company like Taptap Send may be licensed elsewhere, its ability to operate in Ghana hinges entirely on its local partner — the licensed PSP or bank that terminates the transactions.
The BoG’s guidelines and its enforcement actions make it unequivocally clear: the local licensee is the responsible party. When the music stops, it’s the local partner — in this case, fintechs like Flutterwave and Cellulant — that must answer to the regulator and must eventually re-apply for their foreign partners to be reinstated. The foreign MTO is left in a precarious position, its fate tied to its partner’s regulatory standing.
How to Avoid the Next List
So, for a fintech or PSP looking to navigate this landscape without ending up in the next press release, what does the BoG’s updated rulebook dictate?
- Choose Your Partners Wisely (and Do Your Homework): The onus is on the local PSP to conduct extreme due diligence on any foreign MTO. This goes beyond checking a license; it involves verifying its AML/CFT frameworks, its business practices, and ensuring it doesn’t route traffic from unapproved countries. The guidelines explicitly state that the PSP is responsible for the MTO’s good behaviour.
- Segregate Everything: Do not commingle funds. The guidelines mandate distinct settlement accounts, dedicated OVAs, and remittance-specific APIs. Any attempt to blur the lines between remittance flows and other types of transactions is now a glaring red flag for regulators.
- Embrace the Grind of Compliance: The shift to weekly reporting is a signal. Compliance cannot be an afterthought; it must be a core, resourced function. Automated monitoring systems, trained dedicated staff, and robust record-keeping are no longer optional.
- Play a Straight Game: The warning against rebates and “preferential arrangements” is a shot across the bow of growth-at-all-costs strategies. Competing on rate and service is one thing; distorting the market with unsustainable incentives is another, and the BoG has now declared it off-limits.
In the end, the Bank of Ghana’s message is perfectly clear, if one reads beyond the legalistic language of its notices. The era of regulatory ambiguity is over. The guidelines provide a detailed map, and the enforcement actions show the consequences of ignoring it. For the fintech industry, the lesson is that in Ghana, the cost of non-compliance is not just a fine but a very public reputational hit. In the high-stakes game of remittances, the house always wins, and the house is on a mission to ensure everyone plays by its exact rules.