Do you still think stablecoins are just 'crypto versions of electronic wallets'? When they connect fiat currency, cross-border payments, and the DeFi ecosystem, becoming the 'digital bridge' of the financial system, regulation is no longer just a wall but a reconstruction of global financial order. The future of stablecoins will not only depend on technological breakthroughs but also on who comes to 'legislatively define' their value boundaries.
1. Stablecoins have taken the global financial stage, no longer just 'small tools' on the blockchain
Since the second half of 2023, the market value, user numbers, and use cases of stablecoins have exploded, no longer just auxiliary tools for collateralized lending in DeFi but becoming a key hub between the cryptocurrency world and real-world finance. In particular, USD stablecoins (such as USDC and USDT) now account for over 95% of the global stablecoin market value, and their functions in payment, settlement, hedging, and asset transfer are gradually expanding.
As the influence of stablecoins continues to rise, regulatory focus is also rapidly converging. Countries such as the EU, the US, Japan, Hong Kong, Singapore, and the UAE are introducing new regulations, marking the beginning of a regulatory competition on how 'financial sovereignty' and 'financial innovation' can coexist.
2. Five Major Trends in Global Stablecoin Regulation Emerge
1. Payment Attributes Established: Stablecoins are viewed as 'new payment tools'
Regulators in various countries generally position stablecoins as payment-type financial instruments, especially encouraging fiat-backed stablecoins. For example, Singapore and the UAE have incorporated stablecoins into their payment regulatory frameworks for standardized management of issuance and circulation.
2. Licensing System Established: Issuers must be 'certified' and have a physical presence locally
The issuance of stablecoins must meet the qualifications of financial institutions, requiring the establishment of registered entities locally, subject to scrutiny and sanctions by regulatory authorities. Regulatory licenses have become the entry barrier and the core means of risk isolation and post-event accountability.
3. Closer to Bank Regulation: Aligning with commercial banks and payment institutions
Issuers are required to establish capital, governance structures, and operational restrictions to protect users' redemption rights. The EU's MiCA legislation also refers to the rules for 'systemically important financial institutions' to adapt recovery plans for large stablecoins.
4. Redemption Mechanism Clarified: Reserve assets must be stable, custodially isolated, and redeemable at any time
Countries have put forward clear requirements regarding the nature of reserve assets, custody methods, redemption processes, and payment priority order. For example, Circle's reserve structure for USDC must comply with the proportion of U.S. short-term government bonds to ensure 100% fiat asset backing.
5. Anti-money laundering upgrades: Regulatory standards fully aligned with FATF and strictly enforced
The EU has raised the 'travel rule' standard to a zero-threshold implementation, requiring payer information for any amount; Singapore, Hong Kong, and others require all stablecoin trading service providers to fully integrate with AML/KYC systems.
These trends are not just about regulatory 'implementation', but about encoding a new financial order.
3. In-depth Exploration of Core Regulatory Logic: Not just 'copying the banking framework'
Although many countries adopt similar regulatory frameworks for stablecoins as for banks/payment institutions, in reality, the structure, operational logic, and risk characteristics of stablecoins differ significantly from traditional finance:
Decentralized architecture means regulation cannot rely solely on 'entity registration' control but must delve into the underlying protocol design;
Programmability and cross-chain circulation make traditional 'regional territorial regulation' extremely complex;
Visible and verifiable on-chain data instead presents a technological opportunity to establish 'Embedded Supervision'.
This is precisely where the stablecoin research feature on the Mlion.ai platform shines. Through on-chain data modeling, issuance structure identification, and reserve flow tracking, both investors and regulators can form independent risk control perspectives on mainstream stablecoins like USDC and USDT.
4. Key Country Regulatory Practices Review: Who is building standards, and who is observing?
EU: The MiCA legislative comprehensive regulatory framework has been officially implemented, imposing additional capital requirements on 'important crypto assets', making it the most comprehensive stablecoin regulatory paradigm in the world.
United States: Strengthening regulation through payment licenses, congressional bills, and collaboration with SEC/FinCEN; Circle and Paxos are promoted as 'compliance models'.
Japan: The Financial Services Agency has clarified that stablecoins must be issued by banks, trust companies, etc., and **set up specific 'fiat currency asset accounts'** to ensure redemption safety.
Hong Kong: The Monetary Authority is leading the stablecoin regulatory draft, emphasizing compliance pilot projects in cross-border settlement scenarios, and has attracted several institutions to submit applications.
Singapore: MAS has issued clear regulatory guidelines that stablecoins must have 100% fiat support and meet standards such as regular audits.
5. Future Trend Outlook: From 'Regulatory Adaptation' to 'Embedded Regulation'
The regulatory evolution path for stablecoins is not only about rule-making but also an extension of technological revolution:
Regulation will shift from post-approval to embedded contract-based: for example, utilizing on-chain KYC and programmatic redemption rules to automate compliance transactions.
New types of stablecoins (such as RWA-linked and CBDC-compatible) will drive continuous regulatory upgrades;
Algorithmic stablecoins have been largely excluded from global policies, and may be repackaged in the future as a 'half-algorithmic + fiat collateral' hybrid model;
Policy trends will reshape the market landscape; those who first acquire 'compliance qualifications' may become the 'Visa' of the new generation of on-chain payment infrastructure.
Through Mlion.ai's AI news and compliance identification system, you can capture updates on policies from various countries in real-time, identifying project risk exposures, making it an effective assistant for institutions and retail investors to establish cross-border asset allocation frameworks.
6. Conclusion: Stablecoins are not just currencies, but representatives of order
When stablecoins are defined by regulators as 'important crypto assets', they are not only value anchors but also core nodes of financial sovereignty, innovative order, and global competition.
Regulation is no longer about blocking technological innovation but about shaping a future financial order that is trustworthy and accessible. In this process, having a forward-looking perspective and intelligent tools is key to navigating uncertainty and locking in long-term value.
Mlion.ai is the intelligent hub that connects you to this future.
Disclaimer: The content of this article is for informational sharing only and does not constitute any investment or regulatory advice.