The global acceleration in building a stablecoin regulatory framework: A comparison of regulatory policies in Hong Kong and the United States.

Stablecoins, as an important infrastructure in the Crypto Assets market, are gradually breaking through the on-chain ecological boundaries and penetrating into the TradFi system and the operation of the real economy. However, the technological innovations of stablecoins have also brought potential risks. According to reports from on-chain analysis institutions, the total amount of illegal transactions completed through stablecoins reached as high as $40 billion between 2022 and 2023. To balance innovation and risk, global regulatory agencies are accelerating the construction of a systemic regulatory framework for stablecoins.

Stablecoins face two major risks: endogenous risks and external risks. Endogenous risks arise from the stability of stablecoin values relying on the balance of market consensus and trust mechanisms. Once the foundation of trust shows cracks, the stability will quickly collapse. External risks stem from the anonymity and cross-border liquidity characteristics of stablecoins, making them susceptible to exploitation by illegal activities.

Currently, Hong Kong and the United States are rapidly advancing the regulatory framework for stablecoins. Hong Kong submitted the "Stablecoin Regulation Draft" in December 2024, clarifying the definition of stablecoins, regulated activities, issuer admission thresholds, reserve asset management, and other requirements. The United States proposed the "GENIUS Act" and the "STABLE Act," establishing a parallel regulatory system at both federal and state levels.

The regulatory frameworks in both regions focus on aspects such as issuer access, coin value stabilization mechanisms, reserve asset management, and compliance in circulation. Hong Kong requires issuers to have corporate status, meet financial resource requirements, and implement strict management of reserve assets. The United States, on the other hand, stipulates that only approved issuers can issue stablecoins and requires 100% reserve coverage.

With the improvement of the regulatory framework, the stablecoin industry will enter a new stage of balanced development between standardization and innovation. This requires issuers to enhance their compliance capabilities and also provides institutional space for exploring new business models. In the future, the development of stablecoins will find new growth momentum and value creation points within the global financial regulatory system through technological iteration and institutional adaptation.