EMT Safeguarding & Compliance Validator
Verify EMT issuer compliance with MiCA Art. 48, 49, 54, 56 and 58
Art. 48: Issuer Eligibility Check
Only credit institutions and EMIs can issue EMTs. This validator checks issuer type and license validity.
MiCA Compliance Note
Implemented: Art. 48(1)(a) — Issuer must be authorised as a credit institution or an electronic money institution
Implemented: Art. 49(4) — Redemption at any time and at par value; the 1 business day deadline is an example issuer policy, not a MiCA requirement
Implemented: Art. 54 — At least 30% of funds in credit institution deposits (point (a)); the rest in highly liquid instruments in the reference currency (point (b))
Implemented: Art. 56(1) and Art. 43(1) — Significant EMT assessment (at least 3 of 7 criteria), with the Art. 58 consequences for electronic money institutions
Out of scope: Art. 50 — Interest prohibition enforcement requires access to smart contract code and transaction monitoring
Out of scope: Art. 51 — White paper validation requires document parsing and full-text compliance review
Out of scope: Art. 55 — Recovery and redemption plans (Art. 46 and 47 applied to EMT issuers) require legal review and real-time monitoring
What This POC Does Not Implement
- ❌ Smart contract code audit — Real enforcement requires blockchain integration and contract analysis; this POC only validates input parameters
- ❌ Real-time reserve verification — Requires live connections to custodian banks and settlement systems
- ❌ Automated NCA notification — Requires licensed API access to competent authorities
- ❌ Interest/yield detection — Smart contract monitoring requires static analysis tools and runtime analysis
- ❌ Custody audit trail — Real-world segregation verification requires integration with financial infrastructure