As blockchain technology continues to mature and the digital asset market rapidly develops, Real World Assets (RWA) is becoming an important bridge connecting traditional finance and the digital economy.
However, the development of RWA has not been smooth sailing. Governments and regulatory bodies face the challenge of finding a balance between promoting innovation and protecting investors.
Different countries have adopted vastly different policy attitudes towards RWA based on their respective financial systems, legal frameworks, and regulatory philosophies—some embracing it enthusiastically, some cautiously observing, and others imposing strict restrictions.
Hong Kong: The World's Strictest Regulatory Framework Is About to Be Implemented
With the Hong Kong Stablecoin Regulation set to take effect on August 1, 2025, this international financial center is becoming a pioneer in global compliance.
The new regulations not only require issuing institutions to apply for a scarce license (with only a single-digit number to be issued initially) but also mandate 100% reserve isolation and third-party custody to ensure user asset safety. Tech giants like Ant Group and JD.com have entered sandbox testing, and traditional financial institutions like Standard Chartered Bank have formed a consortium to compete for licenses.
However, strict entry conditions (such as a minimum paid-in capital of 25 million Hong Kong dollars) may exclude small and medium-sized institutions, making market concentration inevitable.
The HKMA Chief Executive recently warned the industry to "cool down," suggesting that while regulators are promoting innovation, they have not relaxed their bottom line for risk prevention.
United States: The Dollar Hegemony Ambition Behind Dual-Track Regulation
While Hong Kong is pushing forward with regulations, the GENIUS Act passed by the U.S. Senate reveals a deeper strategic intent.
The act establishes a dual-track regulatory system at federal and state levels: federal regulation of "systemically important stablecoins" with a market value over $10 billion, state-level management of small and medium issuers, while mandating U.S. dollar pegging and banning algorithmic stablecoins.
Treasury Secretary Bessen directly stated that this aims to "consolidate the global status of the U.S. dollar"—by requiring stablecoin reserves to invest in U.S. Treasury bonds maturing within 93 days, the private sector will passively increase U.S. debt holdings, thereby reducing national borrowing costs.
Global Divergence: EU Strict Control vs. Emerging Markets' "Passive Dollarization"
In this regulatory race, different economies are showing a polarized strategy.
The EU has erected a "protective wall" through the MiCA framework, banning non-euro stablecoins for daily payments and delisting coins like USDT to defend euro sovereignty.
In contrast, emerging markets like Turkey and Nigeria, due to local currency depreciation, have effectively made stablecoins "digital dollars" (43% of Nigeria's on-chain transactions involve stablecoins; 10% of Mexico's cross-border remittances are completed via USDC), forcing citizens to struggle between financial innovation and monetary sovereignty loss.
Russia has chosen a different path, postponing the central bank digital ruble to 2026 and instead gradually mandating merchants to accept national digital currency payments, attempting to counter private stablecoin penetration through administrative power.
Conclusion: The Life-or-Death Race Between Compliance and Sovereignty
The Chief Secretary of Hong Kong's Financial Services Bureau, Xu Zhengyu, pointedly stated: "The original intention of stablecoins is to serve the real economy, not to create wealth myths."
Behind this regulatory race lies a battle for monetary sovereignty: the U.S. expanding dollar hegemony through stablecoins, the EU protecting euro integrity, and Hong Kong paving an indirect path for RMB internationalization.
When technological innovation collides with geopolitical competition, the future of stablecoins is no longer just an evolution of financial tools, but a key to reshaping the global financial power landscape.
