Hong Kong’s stablecoin regulations require strict compliance, with limited licenses and third-party custody, fostering innovation while addressing risk control.
The US pushes for dollar dominance with dual regulatory systems for stablecoins, aiming to strengthen its financial position through mandated reserves in US Treasury bonds.
The IMF warns of systemic risks from stablecoins, urging global regulatory cooperation to avoid market fragmentation and ensure financial stability.
With Hong Kong’s new stablecoin regulations taking effect, the global competition for crypto regulation intensifies. Explore how different regions, including the US and EU, are shaping stablecoin futures.
As blockchain technology matures and the digital asset market rapidly evolves, the tokenization of real-world assets (RWA) is emerging as a crucial bridge connecting traditional finance with the digital economy.
However, the development of RWA faces significant challenges. Governments and regulatory agencies worldwide grapple with balancing the dual imperatives of fostering innovation and protecting investors.
Divergent policy approaches have emerged across nations—ranging from proactive embrace to cautious observation and stringent restrictions—shaped by their unique financial systems, legal frameworks, and regulatory philosophies.
Let’s delve into the current RWA regulatory landscapes in key jurisdictions, analyzing the underlying logic and market implications.
HONG KONG: STRICT REGULATORY FRAMEWORK COMING INTO EFFECT
As Hong Kong’s “Stablecoin Ordinance” is set to take effect on August 1, 2025, the city is positioning itself as a global leader in regulatory compliance.
The new regulations require issuing institutions to apply for a scarce license, with only a limited number available.
Additionally, the new rules mandate 100% reserve isolation and third-party custody to ensure the security of user assets.
Major tech giants like Ant Group and JD.com have entered the sandbox testing phase, while traditional financial institutions like Standard Chartered Bank are forming consortiums to vie for licenses.
Notably, Hong Kong has created space for the exploration of the Chinese yuan stablecoin, aiming to carve out a new path in the dollar-dominated stablecoin market.
However, the stringent requirements, such as a minimum paid-up capital of HKD 25 million, may exclude smaller institutions, leading to inevitable market consolidation.
HKMA Chief Executive Eddie Yue recently warned the industry to “cool down,” signaling that while innovation is encouraged, the risk control bottom line remains unchanged.
UNITED STATES: DUAL REGULATORY SYSTEM AND THE DOLLAR’S GLOBAL AMBITION
While Hong Kong is pushing forward with its regulatory framework, the US Senate’s passage of the “GENIUS Act” reveals deeper strategic intentions.
The Act creates a dual-tier regulatory system: the federal government will regulate “systemically important stablecoins” with a market value of over $10 billion, while state-level regulators will oversee smaller issuers.
The Act also mandates that stablecoins be pegged to the US dollar and bans algorithmic stablecoins.
US Treasury Secretary Janet Yellen explicitly stated that the purpose of this move is to “consolidate the global position of the US dollar.” By requiring stablecoin reserves to invest in US Treasury bonds with a maturity of no more than 93 days, private sectors will passively increase their holdings of US debt, which would lower national borrowing costs.
GLOBAL SPLIT: EU’S STRICT CONTROL VS EMERGING MARKETS’ DOLLARIZATION
In this regulatory race, different economic entities have adopted polarizing strategies.
The EU has set up a “protective wall” through its MiCA framework, banning non-euro stablecoins from being used for daily payments and delisting USDT and other coins to protect the euro’s sovereignty.
In contrast, emerging markets like Turkey and Nigeria are experiencing forced dollarization, In Nigeria, 43% of on-chain transactions involve stablecoins,with stablecoins effectively becoming “digital dollars.”
While in Mexico, 10% of cross-border remittances are completed through USDC, as citizens are forced to struggle between financial innovation and the loss of currency sovereignty.
Russia has taken a different route, postponing the implementation of the digital ruble until 2026. Instead, it is gradually forcing businesses to accept payments in the state digital currency, attempting to use administrative power to combat the penetration of private stablecoins.
CONCLUSION: THE RACE BETWEEN COMPLIANCE AND SOVEREIGNTY
As Hong Kong’s Financial Secretary Christopher Hui puts it, “The original intention of stablecoins is to serve the real economy, not to create wealth myths.”
Behind this regulatory race lies a battle for monetary sovereignty:
The US seeks to expand its dollar hegemony through stablecoins
The EU aims to protect the integrity of the euro
Hong Kong is carving a route for yuan internationalization
When technological innovation collides with geopolitical games, the future of stablecoins is no longer just a story of financial tool evolution but also a key to reshaping the global financial power map.
〈Global Stablecoin Regulation Race Accelerates〉這篇文章最早發佈於《CoinRank》。
