Real estate has become one of the most attractive vehicles for criminals seeking to hide money obtained through illegal activity, with an estimated US$48.8 million laundered annually through Ghana’s property market, according to a 2024 report by the US-based financial integrity think tank Global Financial Integrity (GFI).
The findings expose deep vulnerabilities in a sector that many Ghanaians interact with daily — from land purchases and residential rentals to commercial property development — yet one that remains heavily cash-based and poorly supervised.
The Financial Action Task Force (FATF), the international standard-setter for anti-money laundering, has warned that real estate is particularly susceptible to abuse because transactions often involve large sums, complex ownership structures and professionals who may not always verify the true source of a client’s wealth.
A Three-Stage Process
Money laundering in property typically follows three stages: placement, layering and integration.
In the placement stage, illegal money enters the financial or property system — often through a cash purchase, a deposit, or a payment routed through an intermediary.
During layering, the funds are moved through multiple transactions to obscure their origin. Properties may be transferred between companies, sold at unusual prices, or financed through complicated loan arrangements between connected parties.
In the integration stage, the money appears legitimate. The owner may claim the funds came from rent, a property sale, a development project or investment profits.
Common Methods
Criminals and their facilitators use a range of techniques to disguise illicit wealth in property. These include shell companies with no genuine business activity, nominee owners who conceal the true beneficiary, false property valuations, overpriced or underpriced sales, repeated property transfers, and construction projects with inflated costs.
Properties may also be registered in the name of a relative, business partner or company, making the criminal’s involvement difficult to detect on official documents.
A major challenge is identifying the beneficial owner — the person who ultimately owns or controls a property. The name on a document may belong to a company, trustee, nominee or relative rather than the individual who provided the money. The FATF has repeatedly emphasised the importance of beneficial ownership transparency in the fight against money laundering.
Ghana’s Vulnerability
Ghana’s 2024 National Risk Assessment formally rated the construction and real estate sector as high risk for money laundering, citing weak supervision and regulatory gaps. The assessment, conducted using the World Bank tool across 13 working groups, identified the property market as vulnerable because it is heavily cash-based, making it difficult to confirm the source of funds and the identity of the person ultimately benefiting from a property.
Global Financial Integrity’s report, titled Cleaning the Foundations, examined 16 cases reported between 2014 and 2023 covering 24 properties and 510 acres of land. It found that limited beneficial ownership transparency, under-supervised gatekeepers and uneven AML enforcement were key factors enabling illicit financial flows into Ghanaian real estate.
The report recommended operationalising the Real Estate Agency Council (REAC) as a central authority to consolidate oversight of the fragmented regulatory bodies and enhance coordination to curb money laundering.
Under Ghana’s anti-money laundering framework, real estate agents are classified as Designated Non-Financial Businesses and Professions (DNFBPs) — accountable institutions required to conduct customer due diligence and report suspicious transactions to the Financial Intelligence Centre (FIC). The Real Estate Agency Act, 2020 (Act 1047) established REAC to supervise the sector and address money-laundering and terrorist-financing vulnerabilities.
Yet enforcement remains uneven. According to industry analysis, real estate professionals file an extremely low volume of suspicious transaction reports with the FIC, and supervisory responsibility is split across the FIC, REAC and the Lands Commission — creating gaps that criminals can exploit.
Warning Signs
Professionals and members of the public should watch for red flags including a buyer who refuses to provide identification, payments made by unrelated third parties, a company that hides its real owners, a buyer whose wealth does not match their known income, pressure to complete a transaction unusually quickly, and large cash payments without reasonable explanation.
One warning sign alone does not prove criminal conduct. But several together should trigger enhanced checks.
The Human Cost
Money laundering in real estate has consequences far beyond individual transactions. It can inflate property prices and make housing less affordable for ordinary citizens, encourage corruption, strengthen organised crime, increase land disputes, reduce tax revenue and distort competition. A property market controlled by hidden wealth may appear prosperous while ordinary workers struggle to buy or rent homes.
What Must Change
Governments, regulators and professionals all have roles to play. Priorities include strengthening property and company ownership records, requiring real estate professionals to conduct customer checks, limiting unexplained cash transactions, improving cooperation between land registries, banks and the FIC, and protecting whistleblowers who report suspicious conduct.
The fight against money laundering is not the responsibility of government alone. Banks, property professionals, buyers, sellers and members of the public all have a role to play. A person who knowingly helps disguise criminal property may face legal consequences even if they did not commit the original crime.
The goal is not to stop investment. It is to ensure that homes, land and commercial properties are purchased with legitimate funds and used for legitimate purposes — so that Ghana’s property market works for its people, not for those seeking to hide the proceeds of crime.
About the Author
Charles Wundengba is a Ghanaian climate activist, media professional and digital strategist. He serves as Communication Manager for 350 Ghana, part of the global 350.org climate movement, and is CEO of Wundef Media, a content creation and brand management company based in Obuasi. He holds a Master’s degree in Strategic Communication and is pursuing an MPhil in the same field. He is also a blogger, the founder of Wundef.com, Northernghana.net and Healthinfogh.com, and co-founder of Obuasitoday.com.
