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The global stablecoin regulatory competition accelerates.
As blockchain technology continues to mature and the digital asset market develops rapidly, Real World Assets (RWA) tokenization is becoming an important bridge connecting TradFi and the digital economy.
However, the development of RWA has not been smooth sailing. Governments and regulatory agencies face the challenge of finding a balance between promoting innovation and protecting investors.
Different countries have taken vastly different policy attitudes towards RWA based on their own financial systems, legal frameworks, and regulatory concepts — some actively embrace it, some cautiously observe, while others impose strict restrictions.
Hong Kong: The world's strictest regulatory framework is about to be implemented.
As the Hong Kong "Stablecoin Ordinance" comes into 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 single-digit number 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, and traditional financial institutions such as Standard Chartered Bank have formed a consortium to compete for licenses.
However, strict access requirements (such as a minimum paid-up capital of HKD 25 million) may keep small and medium-sized institutions out, and the trend of market concentration is already inevitable.
The President of the Monetary Authority, Yu Weimen, recently warned the industry to "cool down and be calm," suggesting that while the regulatory authorities are promoting innovation, they have not relaxed their bottom line on risk prevention.
United States: The Dollar Hegemony Ambition Behind Dual-Track Regulation
As Hong Kong vigorously promotes the regulations, the "GENIUS Act" passed by the U.S. Senate reveals deeper strategic intentions.
The bill establishes a dual-track regulatory system at the federal and state levels: federal regulation for "systemically important stablecoins" with a market capitalization exceeding $10 billion, while state-level management is for small to medium issuers, simultaneously mandating dollar anchoring and prohibiting algorithmic stablecoins.
Treasury Secretary Becerra 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 in 93 days, the private sector will passively increase its holdings of U.S. debt, thereby reducing the country's borrowing costs.
Global Divergence: EU's Strict Control vs Emerging Markets' "Passive Dollarization"
In this regulatory competition, the strategies of different economies show polarization.
The EU has erected a "protective wall" through the MiCA framework, banning non-euro stablecoins from daily payments and delisting currencies such as USDT to defend the sovereignty of the euro.
Conversely, emerging markets such as Turkey and Nigeria have seen their local currencies depreciate, making stablecoins effectively a "digital dollar" (43% of on-chain transactions in Nigeria involve stablecoins). In Mexico, 10% of cross-border remittances are completed through USDC, forcing the public to struggle between financial innovation and the loss of monetary sovereignty.
Russia has chosen a different approach, delaying 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 measures.
Conclusion: The Life-and-Death Race of Compliance and Sovereignty
The assertion by the Secretary for Financial Services and the Treasury of Hong Kong, Xu Zhengyu, points to the core: "The original intention of stablecoins is to serve the real economy, not to create a wealth myth."
Behind this regulatory competition lies a covert battle for monetary sovereignty: the United States is expanding dollar hegemony through stablecoins, the European Union is safeguarding the integrity of the euro, and Hong Kong is creating indirect battlegrounds for the internationalization of the renminbi.
When technological innovation collides with geopolitical games, the future of stablecoins is not just the evolution of financial instruments, but has become the key to reshaping the global financial power map.