Under the backdrop of Bitcoin hitting new highs, the global stablecoin regulatory framework is becoming increasingly完善

Recently, the price of Bitcoin has set a new historical record. At the same time, the regulatory trends regarding stablecoins globally have also attracted widespread attention. In particular, the latest developments in stablecoin regulation in Hong Kong and the United States mark a gradual improvement of the regulatory framework in this field.

Stablecoins are a special type of virtual asset whose value is usually pegged to a fiat currency (such as the US dollar or the euro), aimed at maintaining a relatively stable price. Currently, the more common stablecoins in the market include USDT and USDC. The Hong Kong Monetary Authority has previously announced the list of participants in the first batch of stablecoin issuer sandbox programs, which includes several well-known companies and financial institutions.

On May 21, the Hong Kong Legislative Council passed the "stablecoin ordinance draft", which aims to establish a licensing system for fiat stablecoin issuers. According to the ordinance, institutions issuing fiat stablecoins in Hong Kong or claiming to be pegged to the Hong Kong dollar for fiat stablecoins issued overseas must apply for a license from the Financial Management Commissioner. The ordinance also stipulates that only licensed institutions can sell fiat stablecoins in Hong Kong, and stablecoins aimed at retail investors must be issued by licensed issuers. It is expected that the ordinance will come into effect within this year, and there will be a transitional arrangement for the industry to apply for licenses and make corresponding business adjustments as required.

Legal experts point out that if the regulation comes into effect, some providers of internationally popular stablecoins may need to apply for local licenses to sell products to ordinary investors in Hong Kong. As the application scope of stablecoins continues to expand, their potential risks (such as redemption runs) have also attracted the attention of regulatory authorities, accelerating the construction of a regulatory framework.

In fact, multiple countries and regions around the world have begun or completed legislative work surrounding stablecoins. For example, the EU's MiCA (Markets in Crypto-Assets Regulation) will be fully implemented on December 30, 2024, providing a comprehensive regulatory framework for various types of crypto assets, including stablecoins. The legislation requires issuers to hold sufficient asset reserves to support the stability of stablecoin prices, thereby preventing systemic financial risks.

In the United States, the Senate recently passed the GENIUS Act with a vote of 66 to 22. Supporters believe that the act will help protect consumer rights and establish industry standards, potentially promoting such cryptocurrencies to become mainstream digital payment and financial tools.

Legal experts indicate that a noticeable global trend can currently be observed: stablecoins are gradually moving from the "gray area" of regulation to a more clear and systematic regulatory framework. Major markets are incorporating stablecoins into traditional financial regulatory logic, and the regulatory focus has shifted from "whether to regulate" to "how to regulate," with particular attention to aspects such as anti-money laundering, source of funds transparency, and on-chain traceability.

Industry insiders point out that the increased activity of stablecoin applications has attracted the attention of regulators in various regions. Regulatory agencies are seeking a balance between market development needs and risk prevention. Taking Hong Kong's "Stablecoin Regulation Draft" as an example, on one hand, by establishing a clear licensing system, it can provide a solid regulatory foundation for the industry, reduce market trial-and-error costs, and encourage compliant innovation; on the other hand, considering the challenges posed by the cross-border nature of stablecoins in terms of financial security, capital flow, and anti-money laundering, legislation is expected to more effectively manage these risks.

Legal experts have summarized three major trends in the current global stablecoin regulatory framework:

1. Licensing access and localization requirements are widespread: Major economies generally require stablecoin issuers to operate with a license and establish local entities, aimed at strengthening local regulatory capabilities and preventing cross-border regulatory arbitrage.

2. Reserve management approaches traditional financial standards: Countries emphasize the liquidity and independent custody of reserve assets, and introduce regular audits, reflecting a strict control over credit risk.

3. Function positioning focuses on payment tools: Regulatory agencies tend to define stablecoins as "payment tools" rather than investment products, limiting their financial intermediation functions, aligning with the regulatory logic of payment institutions.

With the gradual improvement of regulatory frameworks in various countries, the stablecoin market is expected to develop healthily in a more regulated environment, bringing new opportunities and challenges to the digital economy.