Author | Wu Says Blockchain

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This podcast invites Hong Kong senior compliance lawyer Wu Wenqian to conduct an in-depth analysis of the latest effective stablecoin bill in Hong Kong, clarifying multiple misunderstandings in the market. He points out that foreign stablecoins like USDT and USDC are not issued in Hong Kong, and therefore not bound by the new regulations; OTC trading of mainstream stablecoins remains possible in Hong Kong. He also discusses issues related to retail participation, KYC requirements, regulatory approval processes, and the background of large institutions like JD entering the space, along with the strategic reactions of banks and traditional enterprises. Additionally, he analyzes the challenges of applying for stablecoin licenses, the compatibility challenges of the bill with compliance scenarios, and the path differences in cryptocurrency policies between Hong Kong and the US, while also looking forward to the potential and limitations of Hong Kong's stablecoins.

For the complete audio, please search for Wu's talk on mainstream audio platforms at home and abroad. This article does not constitute any investment advice, and the author's views do not represent Wu's talk. Readers should strictly adhere to the laws and regulations of their respective locations.

Clarification of Misunderstandings: The Regulatory Scope of Stablecoin Regulations and Their Relationship with Overseas Projects

Colin: Welcome, Lawyer Wu, to join our podcast. Lawyer Wu previously served as the Legal and Compliance Director at OKX and Huobi and is very familiar with Hong Kong's compliance policies. Recently, the stablecoin bill in Hong Kong was officially issued, attracting great attention and also accompanied by considerable controversy. There have been many discussions in society regarding the details of this bill, especially concerning whether foreign stablecoins will be unable to circulate in Hong Kong and the requirement in the bill that every currency holder must complete KYC, which has also sparked quite a controversy. Therefore, we invited Lawyer Wu to interpret it for everyone.

Lawyer Wu has also communicated with me before, and he believes that there are many misunderstandings about this bill from the outside. How about we first invite Lawyer Wu to introduce what he believes are the core misunderstandings?

Lawyer Wu: Thank you, Colin, for giving me this opportunity to explain these misunderstandings regarding the stablecoin regulations. Here's the thing: the stablecoin regulations in Hong Kong officially took effect on August 1st, and recently I have interacted with many people in the cryptocurrency circle and industry who have expressed concerns about some issues. The first is whether USDT and USDC will be banned in Hong Kong. So first, I need to explain what this regulation is actually about. This regulation regulates stablecoins issued in Hong Kong. That is, if your company or entity issues stablecoins within Hong Kong, you fall under the regulatory scope; the second situation is if you issue stablecoins outside of Hong Kong, but that stablecoin is pegged to the Hong Kong dollar and maintains its stable value, that also falls under the regulatory category; the third situation is if the regulatory agency determines that the currency you issue falls within the stablecoin category, it will also be regulated.

The key point to clarify is that only when issued in Hong Kong, or when stablecoins are pegged to the Hong Kong dollar to maintain their stable value, do they fall within the regulatory scope. Based on this standard, Tether's USDT and Circle's USDC do not need to apply for licenses in Hong Kong. First, they are not issued in Hong Kong; they have no employees or offices in Hong Kong, nor are they pegged to the Hong Kong dollar, so they do not fall under the regulatory scope and do not need a Hong Kong license.

This is the first misunderstanding. The second misunderstanding is believing that trading USDT and USDC in Hong Kong has already been prohibited, meaning that USDT or USDC cannot be traded at all in Hong Kong. But as I just mentioned, the regulation is on the 'issuance of stablecoins.' Here, 'issuance' refers to the initial registration of stablecoins on the blockchain, which is what we commonly call 'minting,' and not the buying and selling behavior. Therefore, buying and selling USDT and USDC in Hong Kong OTC does not fall under the behavior of issuance.

Therefore, conducting USDT and USDC transactions in Hong Kong's OTC market is not within the regulatory scope of this regulation. Although Hong Kong may establish a licensing system for the OTC market in the future, as customs has previously discussed this issue, the OTC license has not yet been issued, and the current stablecoin regulations do not cover OTC transactions.

The third point is about the authority of the Monetary Authority to formulate regulations. One claim is that the Monetary Authority can arbitrarily define certain behaviors as stablecoin issuance, but this is not the case. Even if the Monetary Authority believes that certain behaviors constitute stablecoin activities, it must follow statutory procedures, complete announcements and registrations in Hong Kong, and after an objection period, it can take effect. This indicates that the Monetary Authority cannot arbitrarily define which behaviors require licensing; otherwise, it would be overstepping its authority.

The fourth point is that whether it is recognized as 'issuing stablecoins' in Hong Kong depends on several factors, such as: Whether the management team operates in Hong Kong? Is the issuer or company registered in Hong Kong? Are the maintenance, clearing, or burning actions of the stablecoin conducted in Hong Kong? Are the reserve assets denominated in Hong Kong dollars and stored in Hong Kong banks? These all determine whether a project is recognized as issuing stablecoins in Hong Kong. Therefore, I believe there are many misunderstandings regarding stablecoin regulation that need further clarification.

Regulatory Gap: OTC Trading Regulatory Authority Undetermined, Retail Trading Becomes the Controversial Focus

Colin: So, Lawyer Wu, do you believe that until the OTC bill is introduced, USDT and USDC can still be used or traded in Hong Kong?

Lawyer Wu: Yes, a simple example is that you can see on the HashKey platform that USDT can still be traded. HashKey is a virtual asset trading platform (VATP) that has obtained a license, and currently, USDT can be traded normally on this platform without any issues.

Colin: Understood. So what do you think the future OTC bill might do to regulate these two most mainstream stablecoins?

Lawyer Wu: There is currently no definitive decision. Looking back at history, there was a consultation by customs in 2023, and about six months later, a summary report was released. However, a few months ago, regulatory agencies restarted consultations on OTC. Therefore, the current situation is that the Hong Kong government has not yet determined whether customs or the Securities and Futures Commission (SFC) will regulate OTC.

Previously, I had conversations with some customs officials and relevant government personnel, and there is a possibility that both sides may regulate OTC business. On one hand, retail OTC services like currency exchange shops commonly seen in Hong Kong may be regulated by customs; on the other hand, if it involves self-purchase OTC actions, such as scenarios where trading is facilitated through online platforms, it may be regulated by the Competition Commission (i.e. pricing committee). But currently, there is no clear conclusion on this.

So far, we still do not know whether OTC trading will allow USDT and USDC transactions. The biggest issue is who the trading counterparties are—if they are professional investors or institutional traders, then basically there is no problem and they can conduct such transactions.

But the key regulatory focus is retail investors. Whether retail investors can trade USDT and USDC is still a question mark. Previously, customs consulted on prohibiting retail trading of these two stablecoins. However, when we participated in the consultations, we expressed our concerns to various people in the cryptocurrency circle and some compliance experts: if the future OTC license does not allow trading of USDT, the entire licensing mechanism in Hong Kong will be marginalized. Because currently, the largest trading volume comes from USDT and USDC; if retail investors cannot trade under OTC, it will affect Hong Kong's positioning as an international cryptocurrency financial center and the effectiveness of these licensing systems.

So far, whether retail investors can trade USDT under the licensed mechanism has not been determined. Personally, I hope it is possible, because if trading is not allowed, the impact would indeed be very significant.

Colin: Yes, but from the current perspective, the situation seems not very optimistic. I feel that the regulatory authorities' restrictions on retail investors are still quite conservative. You see, now only four types of currencies are allowed for retail trading, while popular currencies like Solana and BNB have not been approved. Imagining USDT and USDC being approved for retail trading seems somewhat difficult.

Lawyer Wu: This is indeed a problem and may be one of the reasons why the OTC license has not yet been issued. I believe the Hong Kong government has not yet figured out how to regulate retail investors to access USDT and USDC. Back in 2023, everyone expected the license to be issued by the end of the year and was actively promoting and consulting, but there has never been a clear result. Therefore, the retail trading issue is indeed the most core and sensitive part of the entire regulation.

KYC Controversy: Regulations Are Not Mandatorily Stated, But Regulatory Practices Prefer Closed-Loop Models

Colin: Another hot topic this time, besides the question we initially discussed about whether USDT and USDC can be used in the future, is a very controversial point regarding whether currency holders must complete KYC. I believe you must have paid attention to this. Because it seems that whether in the US, Singapore, or the EU's regulations, there is no explicit mandatory requirement for all currency holders to complete KYC. If Hong Kong really requires everyone to complete KYC, to some extent, it would effectively cut off the DeFi-related ecosystem because, at present, it is very difficult for DeFi to ensure that every user completes KYC. What do you think about this matter?

Lawyer Wu: In fact, the current regulations do not clearly stipulate that all currency holders must complete KYC. The regulations do not specify this point. However, in the licensing application process of the Monetary Authority, stablecoin issuers need to explain their business content and operational model to the Monetary Authority before applying. Only after the regulatory agency understands and recognizes these contents will they provide the application form.

This means that the regulatory authority will evaluate whether you are suitable to apply for a license based on the business model you submit. For example, if JD wants to issue stablecoins for trading or settlement within its internal ecosystem, such as buying and selling goods on the JD platform or clearing between merchants, every participant in the transaction must complete real-name authentication on the JD platform.

Therefore, in this scenario, every user using JD stablecoins has already completed KYC. In such a closed-loop environment, I believe the Monetary Authority recognizes this model and believes that JD can issue stablecoins. If there is another business model, for example, if you submit a plan to the Monetary Authority hoping to use stablecoins in the DeFi ecosystem, emphasizing open trading, anonymous users can connect freely, and not performing identity verification of currency holders—then in this case, I believe the likelihood of the Monetary Authority approving your license application will be very low.

I want to emphasize that this is actually another area where misunderstandings can easily arise. Although the law itself does not rigidly stipulate that all stablecoin holders must complete KYC, in practice, the Monetary Authority will approve based on the business model you submit. If you cannot prove that your business has sufficient anti-money laundering and counter-terrorism financing capabilities, it will be difficult to get approved.

This actually depends on the business content and is a 'model-oriented' regulatory logic. So to summarize, the text does not mandatorily state the requirement for KYC, but in the actual approval process, the regulatory agency prefers closed-loop, controllable, and user-identified scenarios.

Large Institutions Are Eager: Why JD, Ant Group, and State-Owned Enterprises Are Applying for Stablecoin Licenses

Colin: Actually, what the law states is quite vague, including what was mentioned in subsequent interviews—unless the licensed entity can prove to the Monetary Authority that it has the capability to combat money laundering and terrorism financing, the identity of every stablecoin holder should be verified by the licensee or a third-party institution. These points were also acknowledged by him later in the interview. So I understand that this KYC requirement was indeed somewhat mandatory at the beginning, is that right?

Lawyer Wu: Yes, that’s right. I believe it is indeed the case that the first one or two institutions that can obtain licenses will certainly need to implement a complete KYC process in a closed-loop environment, which makes it easier to obtain licenses, and there is no doubt about this.

Colin: Yes, in fact, the current situation in Hong Kong is also quite interesting, as you should have noticed. Many banks, including some large Chinese-funded banks, local banks, and several state-owned enterprises, are applying for stablecoin-related licenses. Meanwhile, large internet companies like JD and Ant Group have also joined. Why is there such high enthusiasm? But at the same time, the regulation seems quite cautious, and the number of licenses issued does not appear to be very many. There is a sense that the mainland is very eager, while the regulatory side in Hong Kong remains relatively calm and cautious. What do you think of this situation?

Lawyer Wu: Yes, that's indeed the case. From Hong Kong's current environment, two aspects are worth noting. First is the composition of applicants; currently, many Chinese-funded institutions hope to obtain this license by issuing stablecoins to gain an entry point of 'legitimacy' and also secure a relatively formal market position.

I also see that many listed companies are not just aiming to issue stablecoins; they are more about using stablecoins, RWA, and other cryptocurrency concepts to hype their stocks. This is a direction that many listed companies are currently pushing. Their operations often involve signing some memoranda of understanding (MOU) to create a market imagination space for an upcoming blockchain or stablecoin business, thus attracting investor attention and capital speculation, which are still in the conceptual stage.

However, very few projects that can actually implement stablecoin issuance or have substantial business are currently visible. For example, Hong Kong issued more than a dozen Virtual Asset Trading Platform (VATP) licenses last year, but so far, the most active one remains HashKey, while other platforms' user traffic and trading growth have been relatively slow.

I have also recently communicated with several companies that have already obtained VATP licenses, and they generally have a concern: the market size in Hong Kong is too small. If there are a dozen platforms operating simultaneously, this 'market cake' will appear insufficient, so how can they survive? Therefore, the stablecoin market faces the same problem.

In this case, the strategy of the regulatory authority is to conduct a preliminary screening and understanding during the initial application stage, and will not allow everyone to apply casually. It must first go through a detailed consultation with the Monetary Authority, and only if they recognize that your business model is feasible will they issue the formal application form. Therefore, there are many people wanting to apply for stablecoin licenses and competing for this business, but very few can actually enter the substantive application stage, and the process itself is full of challenges.

Comparison of US and Hong Kong Regulations: Hong Kong is Stable but Conservative, While the US Has Become More Attractive Due to Political Changes

Colin: Understood, Lawyer Wu. Actually, you have previously been responsible for some global compliance matters for exchanges. Recently, the SEC in the United States also released a very significant statement and article, and many people are comparing this with the situation in Hong Kong. From your perspective, do you feel that Hong Kong appears more conservative compared to the US, which has made the industry feel somewhat disappointed? What do you think about this matter?

Lawyer Wu: I think it is more appropriate to say that Hong Kong's attitude towards this industry has actually been consistent from beginning to end, with little change. Hong Kong has always had a relatively pragmatic style; we will not be eager like some countries to rush ahead and launch various licenses or policies, but rather do consultations and research step by step before legislating and establishing a licensing system.

Relatively speaking, the policy fluctuations in the US are more severe. For instance, recently, after Trump regained office, the regulatory environment in the US cryptocurrency industry suddenly became much more lenient. In fact, before Trump regained power, the overall regulatory atmosphere in the US cryptocurrency sector was quite oppressive, leaving many people feeling very disappointed with the US cryptocurrency market.

But after Trump took office, this environment made a nearly 180-degree turn, and many projects and institutions rekindled confidence in the US market. This is also why many people have turned back to the US recently, believing that the environment there is friendlier.

On the other hand, Hong Kong has maintained a relatively stable approach. Our policies and regulatory logic have a certain continuity and won't fluctuate drastically due to political or public opinion changes. From this perspective, if looking for short-term opportunities, the US is indeed more attractive right now; but from the perspective of long-term development and regulatory stability, I believe Hong Kong may actually have more advantages.

Two years ago, looking back at that time, for instance, Binance was facing a lot of pressure, and so was Coinbase; almost all US exchanges were contemplating exiting the US market. The situation at that time was very unfavorable for enterprises, making it difficult for long-term strategic companies to operate in such an environment. Therefore, I believe that in the short term, the outlook for the US may be positive, but from a medium to long-term perspective, especially regarding policy stability, Hong Kong still possesses certain advantages.

Offshore RMB Stablecoins: Differing Definitions from Hong Kong Dollar Stablecoins, Currently Not in Conflict

Colin: Another focus everyone is discussing now is the issue of offshore RMB stablecoins. Currently, the recently issued stablecoin bill in Hong Kong does not impose restrictions on RMB stablecoins, right? What is the essential difference between them and other stablecoins?

Lawyer Wu: In fact, in Hong Kong's stablecoin framework, offshore RMB is not regarded as a stablecoin. Because offshore RMB essentially remains a national legal currency, merely existing in the offshore market, it cannot be classified as the kind of stablecoin we usually understand that exists in the form of crypto assets and is supported by reserves.

For example, there has been discussion in Hong Kong about issuing E-HKD, which is electronic Hong Kong dollars. This actually belongs to central bank digital currency (CBDC) and is a completely different concept from stablecoins issued by commercial institutions. One is the digitization of national sovereign currency, while the other relies on asset reserve mechanisms to support stablecoins. Therefore, I believe these two are different in definition and function, and it appears that they will not produce direct conflicts.

Colin: So do you think that under the current laws, companies like JD have the potential to issue offshore stablecoins denominated in RMB in the future?

Lawyer Wu: It is still hard to say at this moment. The market for offshore RMB stablecoins may have some intersection with the market for ordinary stablecoins, but under the current circumstances, the primary issuance target of Hong Kong stablecoins remains those pegged to the Hong Kong dollar.

As for whether it will develop into a scenario where Hong Kong dollars and RMB can be traded mutually in the future, that is very likely to happen. However, if it is merely designed as a stablecoin using offshore RMB, I believe the regulatory agencies in Hong Kong, especially the Competition Commission, are currently unlikely to accept such a plan.

This may belong to the next stage of exploration rather than the primary focus of current stablecoin issuance. Hong Kong's policy is still focused on stablecoins denominated in Hong Kong dollars. Hong Kong dollar stablecoins remain the current development focus.

Banks Actively Participate: Establishing Teams Driven by Asset Management and Business Expansion

Colin: There is an interesting phenomenon recently, where almost all banks are starting to establish dedicated teams to work on stablecoin-related matters. This is quite special because in other regions, such as the US and Singapore, it is usually cryptocurrency institutions that lead stablecoin development. However, many banks in Hong Kong are entering the scene, and I understand that they are indeed forming teams, whether to prepare for license applications or explore business directions. Have you noticed this phenomenon? Is there any special reason behind it?

Lawyer Wu: I believe that banks are starting to form stablecoin-related teams for two main reasons.

The first reason is that the new stablecoin license mechanism has been introduced, one requirement of which is that if the issued stablecoin is pegged to the Hong Kong dollar, its reserve assets must be stored within the banking system. That means that stablecoin issuers must establish cooperation with banks to manage the reserve assets. Thus, banks must first engage with this industry and understand its operational methods to effectively fulfill the role of reserve custodians. This is a preparation that banks must undertake.

The second reason is market opportunities. We see that in the US, the size of USDT (Tether) is quite large. If Hong Kong's stablecoin business can also grow in the future, it will be a very stable and long-term lucrative business for banks. For banks, this financial service sector, which has real asset backing and strong customer stickiness, holds great commercial appeal.

Additionally, Hong Kong banks are currently facing quite a bit of pressure, such as declining property prices and a shrinking real estate market, which has led to decreased income from traditional businesses. They naturally want to develop some new growth points. In this context, stablecoin business seems particularly worth laying out. Therefore, it is very reasonable and strategically significant for banks to be willing to participate actively.

Competitiveness Doubts: Hong Kong Stablecoins Targeting Compliance Scenarios Find It Hard to Compete with USDT/USDC

Colin: Now there is also a topic everyone is discussing, which is, as you just mentioned, USDT and USDC have been very successful. One primarily circulates in developing countries, while the other has a strong market share in compliance scenarios. So, do you think the stablecoins that emerge under the Hong Kong stablecoin licensing system really have competitiveness? Are they only serving users within their ecosystems, or could they potentially compete with international mainstream stablecoins like USDT and USDC?

Lawyer Wu: I think this question should be viewed from the market structure perspective. Currently, the market share of USDT and USDC is enormous, with almost all cryptocurrency users' trading based on these two stablecoins. If a locally launched stablecoin in Hong Kong, like Meego stablecoin, wants to directly compete with USDT and USDC, it is extremely difficult—this point is beyond doubt.

But the key lies in the fact that the markets and use cases they are targeting may be different. USDT and USDC are more geared towards traditional cryptocurrency users, while the stablecoins issued in Hong Kong may be more inclined towards the development of compliance scenarios.

For instance, in the future, if there are some ODBA (On-Chain Digital Bond Authorization) projects or STO (Security Token Offering) projects, these projects may be restricted to only using locally licensed stablecoins in Hong Kong for trading. This would create a completely independent market ecosystem.

Conversely, trading of USDT and USDC often lacks KYC and real-name processes. If used in certain trading scenarios, such as securities token issuance or in collaboration with the Hong Kong Stock Exchange, it may face obstacles in identity verification and compliance. On the other hand, a compliance stablecoin priced in Hong Kong dollars may not have these issues.

Thus, from the perspective of market segmentation, Hong Kong stablecoins may not directly compete with USDT and USDC in the open market, but they may carve out a new track in compliance application scenarios. In this way, Hong Kong's stablecoins can develop their unique positioning.

Exploring Application Prospects: Stablecoins Need to Find Their Position in Specific Compliance Scenarios

Colin: Regarding regulated stablecoins, what advantages do you think they have compared to traditional payment methods or fiat currencies? For instance, you mentioned that the Hong Kong Stock Exchange may adopt stablecoins in the future, but I find it hard to understand why they would need to use them. Is it really necessary for them? This question I have not thought through clearly; what do you think?

Lawyer Wu: Yes, I believe that from the perspective of traditional cryptocurrency users, like myself, I would surely prefer to use USDT rather than a local stablecoin in Hong Kong. This is very normal. For those who have been using digital currencies for the past few years, USDT and USDC have become the most familiar and commonly used choices.

As for Hong Kong's stablecoins, their development will still depend on whether they can find their application scenarios in the future. When they were first introduced, the regulatory authority established a 'sandbox' mechanism to organize various pilot projects, hoping to explore through some practice—if stablecoins were issued locally in Hong Kong, what kind of business models would develop. These still have not reached a conclusion.

In the foreseeable future, I believe Hong Kong's stablecoins are unlikely to directly confront and compete with USDT and USDC; this is almost certain. As I mentioned earlier, they may need to find uses and development space in another independent track.

However, this also depends on the overall direction of the cryptocurrency market. Currently, besides concepts like RWA (Real World Asset Tokenization) and stablecoins that are relatively active, compared to the DeFi Summer of 2020 and 2021, the NFT boom, and the subsequent meme coin craze, the market seems to have lost a clear direction over the past year or two. Especially after more and more traditional financial (TradFi) institutions entered the market, the market has become more conservative.

Currently, stablecoins may primarily develop in compliance scenarios, such as LGBA (regulated on-chain asset issuance platform) and STO (Security Token Offering) fields. They will form a completely different ecosystem from traditional cryptocurrency circles. My personal view is that these two systems should develop in parallel.

The cryptocurrency circle should continue to maintain its independence and develop in a more decentralized direction, while stablecoins in compliance scenarios represent a completely different development path. In the foreseeable future, I do not see these two being able to merge. Instead, I hope for 'walking on two legs,' each developing its own ecosystem and business direction.

International Anti-Money Laundering Pressure: Will FATF's Audit Affect Hong Kong's Stricter Regulation?

Colin: Lawyer Wu, there is another statement I have not completely confirmed, which is about Singapore's recent stringent expulsion of unlicensed cryptocurrency institutions. It is said to be due to the FATF, which is currently conducting an audit on Singapore. This can be basically confirmed. But there is also another claim that the FATF may conduct a new round of evaluations on Hong Kong next year. If this is true, I wonder if it will have an impact on Hong Kong's cryptocurrency policies, especially the strict requirements for anti-money laundering in this stablecoin bill? What do you think?

Lawyer Wu: I have not heard this claim yet, but if it is indeed the case, I believe it will certainly have some impact. From another perspective, the scrutiny from different regulatory agencies in Hong Kong regarding companies, projects, and banking partners involved in the cryptocurrency field has visibly become stricter.

This can also be felt in reality; for example, some companies that were previously active in the cryptocurrency circle have noticed that the process of opening bank accounts or applying for related licenses, which used to be relatively lenient, has visibly become more challenging in the past six months.

I think this tightening is actually reasonable. In the previous phase, regulation was relatively lax, and many companies and institutions were quite proactive in entering this field, with aggressive actions. But when regulators realized that it may have been too lax, it naturally adjusted towards stricter directions. This is like a cycle—after loosening to a certain extent, problems will arise, followed by a tightening phase; when the tightening lasts too long and the market is suppressed, it will then loosen appropriately.

Therefore, I believe the current regulation in Hong Kong is in a tightening phase of this 'cycle.' If the FATF really intends to conduct a new round of evaluations on Hong Kong, the regulatory aspect may emphasize the soundness of anti-money laundering mechanisms even more, including stricter requirements for the real-name system of stablecoins, KYC mechanisms, and transparency of reserves. This can explain why policies are tending to be conservative in the execution phase.

Market Sentiment Is Recovering: Web2 Companies Entering the Scene, and the Atmosphere in Hong Kong Is Gradually Warming Up, However, Many Are Still in the Preparation Stage

Colin: Finally, let me ask you a question. Since this year, how do you feel about the Web3 atmosphere in Hong Kong? There have been rumors that some institutions in Singapore have begun to shift to Hong Kong; I wonder if you have encountered this situation in your work or life?

Lawyer Wu: Regarding the situation of Singapore's projects coming to Hong Kong, I currently have not encountered much, only a few, but overall, there are not many. On the contrary, I feel that in the last two to three months, the overall atmosphere in Hong Kong has improved significantly compared to the beginning of the year.

Because during the period from the end of last year to the beginning of this year, the atmosphere in the Hong Kong market was relatively cold, as if it were in a stagnant state, and the entire Web3 circle was not very active. But in recent months, with the introduction and gradual implementation of stablecoin policies, I feel that the market has become relatively hot again.

Especially now that many companies originally in Web2, such as some first-party enterprises, brand owners, and even traditional sectors like perfume companies, are starting to plan to enter Web3 and consider issuing tokens or doing digital assets or other on-chain businesses.

Overall, at present, Hong Kong is indeed in a phase of recovering enthusiasm. Everyone is discussing and willing to participate. But it should also be noted that most institutions are still in the 'imagining phase,' meaning they are planning, researching, and conceptualizing, but there are still not many projects that have truly been implemented and started execution.

Personally, I actually prefer to see companies that work quietly, accumulating silently, and suddenly having a mature product or an independent track appear. This is the scenario I look forward to seeing. Only by truly transitioning from concept to practical implementation can the enthusiasm for Web3 turn into real industrial driving force.