a) The Minister for Finance on December 5, 2022, invited holders of domestic bonds to voluntarily exchange GH¢137.3 (US$14.3) billion of the bonds and notes including E.S.L.A and Daakye Bonds for a package of 12 new eligible domestic bonds.

As Director of Audit at the Ghana Audit Service, describe how you would plan and execute an audit of the implementation of Ghana’s domestic debt exchange program as a form of CPD for a section of staff of the Ghana Audit Service.

Planning the Audit

  • Understand the Debt Exchange Program:

    • Review the memorandum of the Debt Exchange Programme authored by the Minister for Finance.
    • Study similar programs implemented in other countries like Russia, Ecuador, and Greece to gain comparative insights.
  • Identify Key Stakeholders:

    • Determine the central institution managing the exchange.
    • Identify the coordinating agencies and committees handling the transaction.
    • Assess the qualifications and expertise of personnel involved in the program.
  • Review Regulatory and Legal Framework:

    • Check compliance with relevant domestic and international financial regulations.
    • Evaluate whether the debt exchange aligns with statutory requirements and fiscal policies.
  • Assess Risk Factors:

    • Identify risks such as exclusion of intended bondholders, misclassification of bonds, and inaccurate financial reporting.
    • Examine the cost implications for the government and the overall economy.
  • Evaluate Control Environment:

    • Review the control measures in place to ensure the credibility of data and records.
    • Assess the financial and operational discipline of the institutions involved.

Executing the Audit

  • Interview Key Personnel:

    • Engage with the Minister of Finance, the Governor of the Bank of Ghana, and other key stakeholders.
    • Understand the rationale, methodology, and implementation process of the program.
  • Verify Documentation and Compliance:

    • Check agreements, modifications, and legal approvals for the debt exchange.
    • Ensure compliance with all financial reporting standards and government policies.
  • Analyze Debt Exchange Transactions:

    • Verify the swap ratios and ensure transparency in bond classification.
    • Conduct sample testing of bonds to confirm their accurate transfer to the new bond list.
  • Review Financial Impact:

    • Assess the financial statements to reflect the effect of the debt exchange on government accounts.
    • Review economic analyses of the program’s long-term impact on fiscal stability.
  • Assess Risk Management Strategies:

    • Evaluate risk mitigation techniques implemented by the government.
    • Review contingency plans in case of bondholder resistance or non-compliance.
  • Finalize the Audit Report:

    • Prepare a comprehensive report with findings, recommendations, and necessary corrective measures.
    • Seek expert opinions where necessary and obtain management representations.
    • Submit the final report for review and approval.
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