China Asset Management's Zhu Haokang: Compliance of stablecoins is becoming a trend, global financial centers reflect each other.

Written by: Zhu Haokang, Head of Digital Asset Management and Family Wealth Management at Huaxia Fund (Hong Kong), Founder of the Asia RWA Working Group

1. Hong Kong: The policy window for stablecoins has officially opened.

On May 21, 2025, the Hong Kong Legislative Council officially passed the Stablecoin Bill, marking Hong Kong as one of the first regions in the world to complete stablecoin legislation. According to the Ordinance, any person who issues fiat-linked stablecoins (e.g. Hong Kong dollar, US dollar) in Hong Kong or promotes them to Hong Kong people must be licensed by the Hong Kong Monetary Authority (HKMA). The regulations specify that stablecoins must be fully reserved 1:1 in cash, short-term treasury bonds and other highly liquid assets, and implement regulatory requirements such as instant redemption mechanism, cold wallet custody and information disclosure.

The Hong Kong Monetary Authority (HKMA) will conduct the review in accordance with the principle of "same rules for the same industry, same risk for the same treatment", and will commence the licensing process once the bill comes into effect. The Hon Duncan Chiu pointed out that Hong Kong is also considering including the renminbi as a legal stablecoin to expand its cross-border functions. Under the Web 3.0 development strategy, Hong Kong is expected to build an on-chain center connecting the clearing and settlement of Hong Kong dollars, RMB and US dollars, and become a "settlement hub" for Asian stablecoins. It is recommended to plan for license applications as soon as possible and reconstruct the compliance framework, especially in line with the HKMA's standards in terms of reserve mechanism, safe depository and redemption arrangements.

2. United States: The legislative framework for stablecoins is becoming increasingly clear.

IN MARCH 2025, THE U.S. SENATE BANKING COMMITTEE PASSED THE GENIUS STABLECOIN BILL. On May 20, the Senate passed a key procedural vote by a vote of 66 in favor and 32 against, bringing the bill to the full House debate. The bill establishes a "licensed issuer" system, which restricts only approved financial institutions to legally issue payment stablecoins. It is worth noting that the U.S. Securities and Exchange Commission (SEC) has made it clear that fiat-backed, redeemable stablecoins are not considered securities, and registration is not required to participate in issuance or trading. This clears the way for mainstream stablecoins to be compliant, and it also means that unlicensed foreign stablecoins may be banned from trading in the United States if they do not comply with regulations.

BEHIND THE GENIUS BILL IS THE U.S. DESIRE TO SEIZE THE LEAD IN THE ON-CHAIN OF GLOBAL RWA (REAL WORLD ASSETS). By promoting the US dollar stablecoin as the "base currency" in the digital age, combined with the US debt as a reserve, the US stablecoin regulatory system is paving a compliance path for the global circulation of US dollar stablecoins, and once passed, the legal stablecoin business in the United States will enter the era of comprehensive compliance review and licensing.

3. Outlook: Compliance of stablecoins becomes a trend, global financial centers reflect on each other.

As stablecoins are regarded as the "settlement layer" of on-chain finance, major global financial centers are engaging in competition and cooperation in both institutional and market aspects. Hong Kong, China emphasizes multi-currency compatibility and regional hub positioning, while the United States formulates strict federal legislation centered on dollar asset anchoring. Coupled with the detailed regulatory requirements for stablecoin issuers outlined in the EU's "Regulation on Markets in Crypto-assets" (MiCA) set to be introduced in 2024, it is expected that various regions around the world will explore mutual recognition mechanisms in cross-border payments and regulatory alignment, jointly building a trustworthy global stablecoin ecosystem.