In July 2026 the Bank of Ghana revoked the Dedicated Electronic Money Issuer (DEMI) licence of Zeepay Ghana Ltd for issuing electronic money without corresponding cash backing, a failure that must be diagnosed before any measure can prevent it recurring in electronic money, and before the reach of such a measure over digital currencies like cryptocurrency can be assessed. In this paper, I examine what electronic money and digital money are, compare how Ghana and other jurisdictions regulate their issuance, diagnose the revocation, propose a preventive measure, and trace its effect on future digital currencies.
What Electronic Money Is
Electronic money is monetary value stored electronically, represented by a claim on the issuer, issued on receipt of funds and redeemable against cash.77 Every unit issued is a debt the issuer owes, and the total is the float.78 Digital money is the wider family within which it sits, distinguished by issuer, form, accessibility and how it moves.79 Cryptocurrency sits at its far edge because nobody issues it and nobody owes anything on it.80
How Ghana and Europe Regulate It
In Ghana, only a bank authorised under Act 930 or a licensed DEMI may issue electronic money.81 A DEMI licence is granted only where the applicant banks its customer float and has written into its Regulations of Incorporation that customer money is held in trust, untouchable on insolvency.82 The issuer must hold the entire float in liquid assets kept apart from its own,83 reconcile those assets daily against what customers, agents and merchants hold, and correct any shortfall.84 It produces those records on inspection.85 Europe requires the same backing but verifies it differently, since the calculations go to the regulator twice a year with the underlying data,86 and where assets fall short the regulator itself must see the position remedied.87 The United Kingdom adopted that regime in 2002.88
Where Zeepay's Shortfall Escaped Notice
Zeepay issued electronic money it could not back, let the shortfall persist, and ignored directives to fund it and wind down.89 Its licence went because that conduct harmed users and providers and threatened the payment system.90 Zeepay is culpable, and so is the design of the law. Ghana asks for reconciliation every day where Europe asks twice a year, yet Ghana receives nothing, because the issuer measures its own shortfall and keeps its own record of it. The Bank of Ghana watched what Zeepay owed in real time through its platform access,91 but saw what Zeepay held only by asking. A shortfall is the gap between the two, and the law gave the regulator sight of one side.
I recommend that the Bank of Ghana issue guidelines on returns92 requiring the bank holding the float account, whose identity it already knows,93 to report that balance directly. The Act already makes that bank report in one situation,94 so nothing new is invented. Daily reconciliation would then be checked against a figure the issuer never touches, and a shortfall would show while still small. Such a rule binds any currency with an issuer holding reserves against a liability, which is why fiat backed stablecoins fall inside it on the principle of same activity, same risk, same regulation.95 It has nothing to bind where nobody issues the token, and disappears for the eCedi, which the Bank of Ghana issues itself.