Cash Transaction Reports in Ghana: CTR and ECTR Thresholds, Deadlines and Filing (2026)
Short answer: Ghanaian accountable institutions must report cash transactions above the threshold the Financial Intelligence Centre (FIC) sets for their sector within 24 hours (section 40 of the Anti-Money Laundering Act, 2020, Act 1044). The FIC's figures are GH¢50,000 for banks and the securities sector and GH¢20,000 for savings and loans companies and microfinance institutions. Commercial banks also file electronic currency transaction reports (ECTRs) on inward and outward transfers above US$1,000, within 24 hours (section 42).
This guide is for Anti-Money Laundering Reporting Officers (AMLROs), compliance teams and core-banking and IT teams at Ghanaian banks, specialised deposit-taking institutions, securities firms and forex bureaus. It is a practical guide, not legal advice. Act 1044 has the FIC set thresholds in consultation with the supervisory bodies and publish them in the Gazette. The figures below are the ones the FIC and the Bank of Ghana publish in their own documents. Confirm the current threshold for each licence you hold.
Ghana's three threshold reports
The FIC's 2022 annual report lists three "threshold" reports among the reports it receives. It notes that threshold reports are filed by banks, savings and loans companies and microfinance institutions "when transactions exceed limits set by FIC/BoG":
| Report | What it covers | Threshold | Who files |
|---|---|---|---|
| Cash transaction report (CTR) | Cash deposits and withdrawals above the sector threshold | By sector (below) | Accountable institutions |
| Electronic currency transaction report (ECTR) | Inward and outward electronic transfers | Above US$1,000 | Commercial banks |
| Currency declaration report (CDR) | Currency carried into or out of Ghana | US$10,000 | Declared at the border; the Customs Division of the Ghana Revenue Authority passes the declarations to the FIC |
The volumes are large. In 2023 the FIC received 2,191,001 CTRs and 1,714,577 ECTRs, and the Customs Division submitted 1,620 CDRs.
CTR thresholds by sector
| Sector | CTR threshold | Source |
|---|---|---|
| Banks | GH¢50,000 | FIC report types page and 2022 annual report; Bank of Ghana and FIC AML/CFT&P guideline (section 1.22) |
| Securities sector | GH¢50,000 | FIC report types page |
| Savings and loans companies | GH¢20,000 | FIC 2022 annual report |
| Microfinance institutions | GH¢20,000 | FIC 2022 annual report |
| Specialised deposit-taking institutions | GH¢20,000 | Bank of Ghana and FIC AML/CFT&P guideline (section 1.22) |
| Forex bureaus | GH¢20,000, on sales and purchases of foreign currency | Bank of Ghana and FIC AML/CFT&CPF guidelines for foreign exchange bureaus (2025) |
| Other accountable institutions | Set by the FIC with the supervisory body | Act 1044, section 40(1) |
The Bank of Ghana and FIC guideline says the thresholds apply to cash transactions "in any currency", at the cedi figure "or its foreign currency equivalent", and "or amounts as may be determined by the FIC from time to time". The FIC's report types page puts the banking rule simply: "any deposit or withdrawal amounting to GH¢50,000.00 or more is reported to the Centre".
Watch the wording: the Act refers to cash transactions that "exceed" the threshold, while the FIC's page speaks of amounts "of GH¢50,000.00 or more". Reporting at the threshold as well as above it satisfies both.
The 24-hour deadline
An accountable institution submits a report to the Centre "within twenty-four hours after carrying out a cash transaction" above its threshold (section 40(2)). The FIC calls the CTR "a mandatory daily report". In practice that means a daily extract of qualifying cash transactions, reviewed and filed on goAML within 24 hours of each transaction.
Linked transactions and structuring
The duty applies "whether the cash transaction is conducted as a single transaction or as several transactions that appear to be linked" (section 40(3)). A customer who deposits GH¢30,000 in the morning and GH¢25,000 in the afternoon at a bank has made GH¢55,000 of cash deposits that day, and a CTR system has to see them together.
Deliberately splitting transactions to avoid a report is prohibited: a person may not conduct two or more transactions separately, with one or more accountable institutions, to avoid the reporting duty (section 39). Doing so is an offence (section 48(1)(h)). Splitting also suggests a suspicious transaction report. Section 38 names transactions "conducted to avoid or give rise to a reporting duty" among its triggers, so a pattern of deposits just under the threshold calls for an STR as well as any CTR. See our STR guide.
Electronic currency transaction reports
Where an accountable institution, through electronic means, transfers currency out of Ghana or receives currency from outside Ghana on behalf of a customer above the amount the Bank of Ghana prescribes, it reports the particulars to the Centre within 24 hours after the transfer or receipt (section 42). The FIC's report types page says the ECTR is "filed by commercial banks only. All inward and outward transfers exceeding US$1000.00 are reported."
The Bank of Ghana and FIC sanctions schedule calls the same report an "Electronic Transfer of Currency Report (ETCR)". Both names refer to the section 42 report.
How to file
Reports under sections 40 and 42 are made "in a manner prescribed by the Centre". The Centre may ask for more information about a report it has received, and it issues guidelines on the procedure for, and form of, these reports (section 43). The FIC receives cash transaction reports through its goAML portal, reporting.fic.gov.gh. Its 2022 annual report links the jump in threshold reports that year to the onboarding of most financial institutions onto goAML.
At daily volumes in the thousands, CTRs and ECTRs are best generated from core-banking data as goAML XML, not keyed into web forms. Validate each file against the schema before upload so the batch is not rejected. For registration, see our FIC goAML registration guide.
Customer due diligence and records
The threshold also triggers customer due diligence. An accountable institution applies due diligence to occasional transactions above the section 40 threshold, including linked transactions (section 30(2)(b)).
Copies of CTRs and other reports are kept for at least five years from the date of the report, and transaction records for at least five years from the date of the transaction, detailed enough to reconstruct each transaction (section 32).
A report made in good faith also protects the reporter. No criminal action for money laundering or related offences may be brought against a person in connection with executing a transaction reported in good faith under section 40 or 42 (section 44(2)).
Penalties
| Failure | Consequence |
|---|---|
| Not submitting a report under section 40 or 42 within the time limit (section 48(1)(e)) | Fine of 500 to 4,000 penalty units, or six months to five years' imprisonment, or both |
| Not submitting a CTR, or giving a misleading, false or incomplete statement, or concealing a material fact; failing to inform the Centre of an electronic transfer (section 48(2)(e)–(g)) | Fine of 1,000 to 10,000 penalty units, or 12 months to five years, or both; for a company, 5,000 to 50,000 penalty units (section 48(3)) |
| Structuring to avoid a report (section 48(1)(h)) | As for 48(1) |
| Administrative penalties | The Bank of Ghana and FIC schedule sets 500 to 20,000 penalty units against the AMLRO for failing to file CTRs or electronic transfer reports, within the section 53 powers |
CTR and ECTR checklist
- List every licence your group holds and the threshold that applies to each.
- Aggregate each customer's cash transactions across branches and channels for the day, so linked transactions reach the threshold together.
- Report at the threshold as well as above it, in cedis or the foreign-currency equivalent, with the conversion rate recorded.
- Generate the day's CTRs, and ECTRs for commercial banks, as goAML XML, validate them and file within 24 hours.
- Flag patterns just under the threshold for STR review.
- Keep copies of every report for at least five years from the date of the report.
- Review the thresholds whenever the FIC or your supervisor issues a new figure.
Frequently asked questions
What is the cash transaction reporting threshold in Ghana?
It is set by sector. The FIC gives GH¢50,000 for banks and the securities sector and GH¢20,000 for savings and loans companies and microfinance institutions. The Bank of Ghana and FIC guidelines give GH¢20,000 for specialised deposit-taking institutions and for forex bureaus' sales and purchases of foreign currency.
When is a cash transaction report due in Ghana?
Within 24 hours after carrying out the cash transaction (section 40 of Act 1044). The FIC calls the CTR a mandatory daily report.
What is an ECTR?
An electronic currency transaction report: the section 42 report on electronic transfers of currency into or out of Ghana. The FIC says it is filed by commercial banks only, for inward and outward transfers exceeding US$1,000, within 24 hours.
Do linked transactions count towards the threshold?
Yes. Section 40(3) applies the reporting duty to cash transactions conducted as a single transaction or as several transactions that appear to be linked, and section 39 prohibits splitting transactions to avoid a report.
What is a currency declaration report?
The declaration made at the border by a person carrying currency into or out of Ghana above the amount the Bank of Ghana prescribes (section 41). The FIC gives the threshold as US$10,000, and the Customs Division of the Ghana Revenue Authority passes the declarations to the FIC.
Automating CTRs and ECTRs with Creodata
Creodata's goAML Reporting Platform holds each FIU's thresholds, identifiers, channel codes and validation rules as a country profile, generates schema-valid goAML XML from core-banking data, and validates every file before it reaches the portal. It also keeps an immutable record of every report, amendment and filing. See goAML reporting software for Ghana, and AML compliance software in Ghana for the monitoring and case management behind each report.
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More guides for Ghana
- Ghana FIC goAML Reporting: STR, CTR and ECTR Rules for Banks (2026)
- FIC goAML Registration in Ghana: Who Registers, How Onboarding Works and What to Prepare (2026)
- Suspicious Transaction Reports in Ghana: The FIC's 24-Hour Rule, Triggers and Tipping-Off (2026)
- Ghana's Anti-Money Laundering Act, 2020 (Act 1044) Explained: What Accountable Institutions Must Do
- AML Compliance Software in Ghana: A Buyer's Guide for Banks, SDIs, Fintechs and DNFBPs (2026)