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The shocking gap in Ghana’s market surveillance

Introduction

Ghana’s capital market is expected to operate on principles of fairness, transparency, and efficiency. At the center of this mandate is the Securities and Exchange Commission (SEC), specifically its Exchanges and Markets Department, which is responsible for monitoring trading activities and ensuring market integrity.

But a key revelation from the SEC’s 2024 Annual Report raises an important question: How effectively can a modern capital market be supervised without modern surveillance tools?


No Dedicated Surveillance System in Ghana's Stock Market
No Dedicated Surveillance System in Ghana's Stock Market

The Reality: No Dedicated Surveillance System

According to the SEC 2024 Annual Report (page 63), the department responsible for overseeing trading activity does not have a dedicated market surveillance system in place.

Instead:

  • Microsoft Excel is used for trade analysis

  • The Ghana Stock Exchange’s Post Trade Reporting System (PTRS) is used for reviewing transactions

As stated in the report:

“There is no surveillance software available for the department to review market data. Microsoft Excel and the Post Trade Reporting System (PTRS) of the GSE are used to review trades.”

This means that one of the most critical regulatory functions in Ghana’s capital market is being carried out using tools that are largely manual and reactive.


What This Means for Market Oversight:


1. A Reactive Instead of Proactive System

Without real-time surveillance tools, monitoring happens after trades are executed, not during. This limits the ability to detect suspicious behavior as it happens.


2. Limited Detection of Market Abuse

Advanced surveillance systems typically detect:

  • Insider trading

  • Market manipulation

  • Unusual trading patterns

With Excel-based reviews, detection depends heavily on manual effort and predefined checks, increasing the risk of oversight gaps.


3. Scale vs Capacity Challenge

The report shows that:

  • 1,149 trades were flagged as “marking the close”

  • 51 large orders were identified

Yet no infractions were found.

This raises a key concern:Is the absence of detected abuse a reflection of market integrity or limitations in detection capability?


4. Global Standards Are Moving Ahead

Globally, regulators are increasingly adopting SupTech (Supervisory Technology), including:

  • Artificial Intelligence (AI)

  • Machine Learning (ML)

  • Big data analytics

These tools enable regulators to detect patterns, flag anomalies, and act in real time. Ghana’s reliance on Excel highlights a widening gap between local regulatory tools and global best practices.


A System in Transition

Interestingly, the same report signals awareness of this gap.

The SEC’s IT road map includes plans to:

  • Procure and implement a market surveillance system

  • Improve real-time oversight and risk mitigation

This suggests that while the current state is limited, there is a clear direction toward modernization.


Why This Matters for Investors

Market surveillance is not just a regulatory function. It is the foundation of investor confidence.

Weak surveillance systems can lead to:

  • Undetected market abuse

  • Reduced trust in the market

  • Lower participation from institutional investors

On the other hand, strong surveillance systems:

  • Enhance transparency

  • Improve market integrity

  • Attract both local and foreign investment


The Bigger Picture

Ghana’s capital market is growing, with increasing activity across equities, bonds, and commodities. But growth in market activity must be matched with growth in regulatory capability.

The gap is clear:

  • Market complexity is increasing

  • Surveillance tools are lagging

Bridging this gap is not optional, it is essential.


Conclusion

The revelation that Ghana’s capital market surveillance relies on Excel is more than a technical detail it is a strategic issue.

It highlights:

  • A critical infrastructure gap

  • A risk to market integrity

  • And an opportunity for transformation

As the SEC moves toward implementing modern surveillance systems, the future of Ghana’s capital market will depend on how quickly and effectively this transition is executed.


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