Stablecoins, the product form closest to RWA in crypto finance, are facing an unprecedented regulatory transformation. On June 18, 2025, at dawn, the US Senate passed the GENIUS Act (Giving Every Nation a United Stablecoin) with 68 votes in favor and 30 against, marking the first time the United States has established a clear regulatory path for stablecoins at the federal level, signaling a critical turning point for crypto assets from technical experimentation to institutionalization. Note: Currently pending in the House of Representatives
Simultaneously, Hong Kong has made forward-looking arrangements through the Stablecoin Ordinance and future related license applications, and will officially begin accepting stablecoin issuance license applications on August 1, becoming the world's first financial center to implement a local stablecoin licensing mechanism.
The new compliance cycle represented by the United States and Hong Kong may profoundly reshape the position of stablecoins in the global financial system, and the underlying currents behind these variables are accelerating to the forefront.
01 United States: Firing the First Shot in Stablecoin Regulation
Over the past 5 years, what has been the most successful crypto financial product globally?
The answer is not difficult to guess - neither Uniswap and other on-chain financial innovations that sparked DeFi Summer, nor digital artworks like CryptoPunks that triggered the NFT boom, but rather the stablecoins that everyone has long been accustomed to.
Indeed, beyond DeFi, NFT, and other inherently whale-oriented games, stablecoins targeting ordinary users have become one of the widely accepted use cases for both crypto and non-crypto users, gradually becoming an important bridge for on-chain payments, cross-border settlements, financial transactions, and even Web2 scenarios, greatly expanding and deepening the user base of the crypto economy.
Objectively speaking, their widespread application has always been in a gray area - lacking unified regulation, opaque reserve mechanisms, and unclear legal attributes, becoming key obstacles to institutional entry and mainstream adoption.
As a bellwether for global financial rules, the US GENIUS Act's passage is undoubtedly a milestone. The act first comprehensively regulates stablecoins at the federal level, defining stablecoins, issuing qualifications, reserve mechanisms, and user rights. Key points include mandatory 1:1 reserve support, requiring all issuers to maintain fiat currency reserves equal to issued stablecoins, with users able to redeem their stablecoins at 1:1 at any time.
Issuance qualifications are limited to banks, licensed non-bank financial institutions, and compliant audited enterprises, applicable to a wide range of objects including corporate settlement stablecoins and consumer payment stablecoins. This means that stablecoin businesses long operating in gray areas will first enter a "rule-of-law, rule-following" institutional track, with profound implications for companies like Circle, PayPal, and JPMorgan pushing stablecoin businesses.
As the only stablecoin issuer currently listed on US stocks, Circle has been rising since its IPO on June 5, soaring from its issue price of $31 to a high of $263.45, joining heavyweight players like Coinbase and Robinhood.
More notably, Circle's market value once approached $60 billion, equivalent to the total circulating market value of its issued USDC, undoubtedly marking a revaluation of the market's pricing logic for compliant stablecoins.
This also indicates that the imagination of "stablecoin compliance" is no longer limited to Web3 but beginning to project into mainstream financial narratives. Regardless of its subsequent actual direction, this is a turning point for crypto assets to further enter the mainstream view and obtain a legitimate, compliant framework.
02 Hong Kong: Leading the Way with Licensing, Accelerating Implementation
Since publishing the "Policy Declaration on Virtual Asset Development in Hong Kong" on October 31, 2022, Hong Kong has consistently been at the forefront of crypto regulation among major jurisdictions.
As early as January 2022, the Hong Kong Monetary Authority released a discussion document on crypto assets and stablecoins, inviting stakeholder feedback. Early last year, it launched a stablecoin issuer "sandbox" to understand the business models of institutions planning to issue fiat stablecoins in Hong Kong.
The latest Hong Kong Stablecoin Ordinance will take effect on August 1, at which point the Hong Kong Monetary Authority will begin accepting license applications. Currently, the authority has initiated market consultation on specific guidelines for implementing the Stablecoin Ordinance.
Based on currently disclosed information, the key institutional design adheres to the principle of "same activity, same risk, same regulation", including requirements for issuers to apply for stablecoin issuance licenses from the Monetary Authority, establish local registered entities, ensure assets are fully pegged to total issuance, and maintain reserve assets in highly liquid fiat or short-term government bonds.
It can be said that the regulatory dimensions and mechanisms are largely similar to those of the United States. Notably, the Hong Kong regulatory system applies to stablecoins pegged to major currencies like USD and HKD, with the policy core aimed at providing a stable clearing and settlement medium for Web3 finance while attracting more institutions to establish stablecoin businesses in Hong Kong.
As an international financial center, Hong Kong has always been actively exploring paths of financial innovation, and the stablecoin market is somewhat its comfort zone - with a rich range of financial service industries, years of accumulation and experience, mature risk control systems, comprehensive trading infrastructure, and a massive customer base.
This makes Hong Kong emphasize flexible implementation and international alignment more than the United States, attracting more institutions to use Hong Kong as a springboard to explore stablecoin clearing and issuance paths in the Asian market. Currently, local heavyweight players like HashKey and OSL are reportedly preparing or laying out applications for stablecoin licensing, becoming an important entry point for observing Hong Kong's crypto compliance and financial infrastructure integration.
03 Blooming in Multiple Regions like EU and South Korea
Additionally, the EU's Markets in Crypto-Assets (MiCA) Regulation, effective in 2024, comprehensively covers crypto asset compliance regulation, providing detailed classification of stablecoins, including Electronic Money Tokens (EMT) and Asset Reference Tokens (ART).
The former refers to stablecoins pegged to a single fiat currency, such as Circle's EURC, while the latter refers to stablecoins anchored to a basket of assets, like the failed Libra type. EMT stablecoins require authorization from EU electronic money institutions, are subject to central bank supervision, must disclose reserve composition and execution mechanisms, and ensure user redemption rights. Circle's EURC is among the first beneficiary products after MiCA implementation.
In South Korea, with significant influence in the Crypto domain, the ruling party of the new president Lee Jae-myung proposed the "Digital Asset Basic Law", clearly stipulating that Korean companies with at least 500 million won (about $370,000) in capital and ensuring refund guarantees through reserve funds can issue stablecoins.
According to the Bank of Korea, stablecoin trading volume has surged, with the first quarter's major dollar stablecoin trading volume reaching 57 trillion won (about $42 billion) across five major domestic exchanges (Upbit, Bithumb, Korbit, Coinone, and Gopax).
Recently, the Bank of Korea's high-ranking deputy governor Yu Sang-don also stated that introducing won-denominated stablecoins should be gradual, starting with the most strictly regulated commercial banks issuing won stablecoins, and then gradually opening to non-banking institutions.
Moreover, several major financial centers have previously released local stablecoin frameworks or pilot projects:
- Singapore's MAS proposed a stablecoin regulatory draft in 2023, emphasizing 1:1 reserves, transparent disclosure, and local operation requirements;
- Abu Dhabi Global Market (ADGM) launched a stablecoin clearing settlement pilot, attracting cross-border businesses like PayPal and USDC;
- Japan passed a new law allowing banks and trust companies to issue stablecoins;
Overall, European regulation focuses on protecting user rights and financial stability, while South Korea leans towards exploring with local financial and tech giants. This signifies the global stablecoin regulatory system gradually moving towards unified standards and indicates that stablecoins are no longer in a gray area but are being viewed as a formal component of financial innovation, with their regulatory testing grounds becoming an important capital policy tool for attracting Web3 projects.
Dialectically, from 2025, whether crypto asset ETFs or stablecoins, a new regulatory cycle has become a clear watershed for Web3 and crypto industry development. Especially when compliance becomes the main theme of the next stage of stablecoin development, each country's institutional exploration not only influences market patterns but also profoundly shapes the future infrastructure of Web3 finance.
It can be said that globally, stablecoins are experiencing a dramatic transformation from "wild expansion" to "institution-led", and the landscape reconstruction under this massive change is comprehensively unfolding with the landing of regulations from various countries.
