The global stablecoin regulatory competition accelerates.

CN
10 hours ago

With the continuous maturation of blockchain technology and the rapid development of the digital asset market, Real World Assets (RWA) are becoming an important bridge connecting traditional finance and the digital economy.

However, the development of RWA is not without challenges. Governments and regulatory agencies around the world face the challenge of finding a balance between promoting innovation and protecting investors.

Different countries have adopted vastly different policy attitudes towards RWA based on their respective financial systems, legal frameworks, and regulatory philosophies—some actively embrace it, some cautiously observe, while others impose strict restrictions.

Hong Kong: The World's Strictest Regulatory Framework is About to Launch

As the Hong Kong "Stablecoin Ordinance" is set to take effect on August 1, 2025, this international financial center is becoming a pioneer in the global compliance process.

The new regulations not only require issuing institutions to apply for scarce licenses (with only a handful issued in the first batch) but also mandate 100% reserve isolation and third-party custody to ensure the safety of user assets. Tech giants like Ant Group and JD.com have entered sandbox testing, while traditional financial institutions like Standard Chartered Bank have formed consortiums to compete for licenses.

However, strict entry requirements (such as a minimum paid-up capital of HKD 25 million) may keep small and medium-sized institutions out, making market concentration an inevitable trend.

The President of the Monetary Authority, Eddie Yue, recently warned the industry to "cool down," suggesting that while the regulatory body is promoting innovation, it has not relaxed its bottom line on risk prevention.

United States: The Dollar Hegemony Ambition Behind Dual-track Regulation

While Hong Kong is vigorously advancing its regulations, the U.S. Senate's passage of the "GENIUS Act" reveals deeper strategic intentions.

This act establishes a dual-track regulatory system at the federal and state levels: federal regulation for "systemically important stablecoins" with a market value exceeding $10 billion, and state-level management for smaller issuers, while mandating a dollar peg and prohibiting algorithmic stablecoins.

Treasury Secretary Janet Yellen stated that this move aims to "consolidate the global position of the dollar"—by requiring stablecoin reserves to invest in U.S. Treasury bonds maturing within 93 days, the private sector will passively increase its holdings of U.S. debt, thereby reducing national borrowing costs.

Global Divergence: EU Strict Control vs. Emerging Markets' "Passive Dollarization"

In this regulatory race, the strategies of different economies show a polarization.

The EU has erected a "protective wall" through the MiCA framework, prohibiting non-euro stablecoins from being used for daily payments and delisting currencies like USDT to defend the sovereignty of the euro.

In contrast, emerging markets like Turkey and Nigeria, due to currency depreciation, have seen stablecoins become a de facto "digital dollar" (43% of on-chain transactions in Nigeria involve stablecoins), with 10% of cross-border remittances in Mexico completed through USDC, forcing the public to struggle between financial innovation and the loss of monetary sovereignty.

Russia has chosen a different path, postponing the implementation of the central bank digital ruble until 2026, and instead mandating merchants to accept state digital currency payments in phases, attempting to counter the penetration of private stablecoins through administrative power.

Conclusion: The Life-and-Death Race of Compliance and Sovereignty

The assertion by Hong Kong's Secretary for Financial Services and the Treasury, Christopher Hui, highlights the core issue: "The original intention of stablecoins is to serve the real economy, not to create wealth myths."

Behind this regulatory race lies a covert battle for monetary sovereignty: the U.S. expands dollar hegemony through stablecoins, the EU protects the integrity of the euro, while Hong Kong opens a roundabout battlefield for the internationalization of the renminbi.

When technological innovation collides with geopolitical games, the future of stablecoins is not just a history of financial tool evolution but also a key to reshaping the global financial power landscape.

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