Ghana’s real estate sector is one of the country’s fastest-growing economic sub-sectors. The market recorded significant momentum in 2024, with residential building permits rising by 15% year-on-year and commercial property values in Accra and Kumasi climbing by an average of 12%. Luxury residential properties in prime Accra neighbourhoods, Airport Residential, Cantonments, East Legon, and Osu, are now valued between USD 450,000 and USD 600,000, a 20–25% increase since 2020. Foreign direct investment into the property sector rose 18% in 2024.
Despite this dynamism, the sector also faces one of the most severe vulnerabilities to financial crime. Ghana lost an estimated USD 54.1 billion to illicit financial flows (IFFs) between 2013 and 2022, ranking third in sub-Saharan Africa according to Global Financial Integrity’s 2026 Trade-Related IFFs in Africa report. A significant portion of these flows is channelled into tangible assets, with real estate being the most favoured destination for laundered money both globally and locally.
GFI’s new policy brief provides key recommendations:
- Issue an LI under Act 1044 to explicitly designate property developers and valuers as accountable institutions (DNFBPs) subject to CDD and STR obligations.
- Operationalize mandatory BO cross-referencing between the ORC Central Register, REAC RETC process, and the Lands Commission for all corporate real estate transactions.
- Launch a joint FIC and REAC STR compliance campaign for all licensed real estate professionals, including training, anonymous reporting pathways, and published compliance targets.
- Establish a Real Estate AML/IFF Supervisory Coordination Committee (FIC, REAC, Lands Commission, ORC, GRA) via a dedicated LI, with a joint inspection mandate and published annual report.
- Publish Ghana-specific real estate ML red-flag guidance, updated biennially, as a mandatory practitioner training resource for REAC license renewal.
- Integrate the RETC database, Lands Commission register, ORC BO Register, FIC goAML platform, and GRA tax clearance systems into a unified digital real estate transaction intelligence platform.
- Commission a standalone Real Estate Sector ML/TF Risk Assessment in advance of Ghana’s Third Round of Mutual Evaluation, providing a sector-specific evidence base for supervisory resource allocation.
- Support REAC to develop human resource, financial, and technical capacity commensurate with its AML supervisory mandate, including dedicated AML compliance officers and an inspection function.