The global digital asset market welcomes a new rise driven by regulation.

With the United States and Hong Kong successively introducing stablecoin-related legislation, the global digital asset market has officially entered a new rise driven by regulation. These regulations not only fill the regulatory gap for stablecoins anchored to fiat assets but also provide a clear compliance framework for the market, including reserve asset segregation, redemption guarantees, and anti-money laundering compliance requirements, effectively reducing systemic risks.

This article will deeply analyze the core framework of the two major bills, combining quantitative forecasts to systematically look ahead at the growth trajectory of compliant US dollar stablecoins over the next decade and their reconstructive effects on the public chain ecosystem.

1. The Rise of Dollar Stablecoins under the US GENIUS Act and Quantitative Derivation

The "GENIUS Act" (Guiding and Establishing National Innovation for U.S. Stablecoins Act), passed by the U.S. Senate in May 2025, marks a crucial step in the regulation of stablecoins in the United States. The act establishes a detailed regulatory framework for stablecoin issuers, requiring them to maintain reserves backed by highly liquid assets such as cash in U.S. dollars, short-term U.S. government bonds, or government money market funds at a ratio of at least 1:1, and to undergo regular audits while complying with anti-money laundering (AML) and know your customer (KYC) requirements. Additionally, the act prohibits stablecoins from offering interest yields, restricts foreign issuers from entering the U.S. market, and clarifies that stablecoins are neither securities nor commodities, thereby providing a clear legal positioning for digital assets. This legislation aims to enhance consumer protection, mitigate financial risks, and provide a stable regulatory environment for fintech innovation.

The implementation of the GENIUS Act is expected to have a profound impact on the global cryptocurrency market landscape. Firstly, investment in high liquidity dollar assets that do not allow for interest will directly benefit the issuance of U.S. Treasury bonds, making stablecoins an important channel for the distribution of these bonds. This mechanism not only alleviates the financing pressure of the U.S. fiscal deficit but also strengthens the international settlement position of the dollar through digital currency channels. Secondly, a clear regulatory framework may attract more financial institutions and technology companies to enter the stablecoin field, promoting innovation and efficiency improvements in payment systems. However, the Act has also sparked some controversies, such as potential conflicts of interest arising from the Trump family's involvement in the cryptocurrency industry, and the international regulatory coordination issues that may arise from restrictions on foreign issuers. Nevertheless, the GENIUS Act provides institutional guarantees for the development of stablecoins, marking an important step for the United States in the global competition of digital asset regulation.

According to a prediction by a financial institution, under a scenario of clearer regulatory paths, the global stablecoin market capitalization is expected to rise from $230 billion in 2025 to $1.6 trillion by 2030. Notably, this prediction implies two key assumptions: first, compliant stablecoins will accelerate the replacement of traditional cross-border payment channels, saving approximately $40 billion in international remittance costs each year; second, the locked amount of stablecoins in DeFi protocols will exceed $500 billion, becoming the foundational liquidity layer of decentralized finance.

II. Differentiated Positioning of the Regulatory Framework for Stablecoins in Hong Kong

The recent release of the "Stablecoin Regulation" by the Hong Kong SAR government marks an important progress in its systematic layout in the Web3.0 field. The regulation establishes a licensing system for the issuance of stablecoins, requiring issuers to obtain permission from the Hong Kong Monetary Authority (HKMA) and meet strict requirements in areas such as reserve asset management, redemption mechanisms, and risk control. In addition, Hong Kong plans to launch a dual licensing system for over-the-counter (OTC) and custody services within the next two years, further improving the comprehensive regulatory system for virtual assets. These measures aim to enhance investor protection, increase market transparency, and consolidate Hong Kong's position as a global digital asset center.

The Hong Kong Monetary Authority plans to release operational guidelines on the tokenization of real-world assets (RWA) in 2025, promoting the on-chain tokenization process of traditional assets such as bonds, real estate, and commodities. By utilizing smart contract technology, functions such as automatic dividends and interest distribution will be realized. Hong Kong is committed to building an innovative ecosystem that integrates traditional finance with blockchain technology, opening up broader application space for the development of Web 3.0. Under Hong Kong's regulatory framework, the issuance of stablecoins will show a prosperous development trend with multiple currencies and scenarios, further consolidating Hong Kong's position as a fintech hub.

The Hong Kong "Stablecoin Regulation Draft" draws on American regulatory logic, but presents significant differences in implementation details:

1. Issuers: Only banks or approved non-bank financial institutions are allowed to issue in the United States, while there are no special restrictions on issuers in Hong Kong.
2. Reserve Assets: The United States requires 100% cash in USD or short-term government bonds, while Hong Kong allows a broader range of highly liquid assets.
3. Interest: The United States prohibits the payment of interest, while Hong Kong has no clear regulations.
4. Foreign issuers: The United States restricts foreign issuers from entering the market, while Hong Kong has no special restrictions on this.
5. Legal Qualification: The United States clearly defines stablecoins as neither securities nor commodities, while Hong Kong has not made a clear definition.

3. The Evolution of the Global Stablecoin Landscape Under Regulatory Competition

(1) The strengthening effect of the US dollar stablecoin as a global reserve currency

Under the regulatory framework established by the GENIUS Act, payment-based stablecoins must use U.S. Treasury bonds as reserve assets. This provision gives U.S. dollar stablecoins strategic significance beyond the realm of digital currency. Essentially, these stablecoins have become a new distribution channel for U.S. Treasury bonds, creating a unique funding loop system globally: when global users purchase stablecoins denominated in U.S. dollars, the issuing institutions are required to allocate the corresponding funds as Treasury bond assets. This not only facilitates the return of funds to the U.S. Treasury but also, in an intangible way, strengthens the global usage breadth of the U.S. dollar. This mechanism can be seen as a global extension of the U.S. dollar financial infrastructure.

From the perspective of international settlement, the emergence of stablecoins marks a paradigm shift in the US dollar clearing system. Under the traditional model, the cross-border flow of the US dollar heavily relies on interbank settlement networks such as SWIFT, whereas blockchain-based stablecoins directly embed into various compatible distributed payment systems in the form of "on-chain US dollars." This technological breakthrough enables dollar settlement capabilities to no longer be confined to traditional financial institutions. This not only expands the international use cases of the US dollar but also represents a modernization upgrade of US dollar settlement sovereignty in the digital age, further consolidating its core position in the global monetary system.

(2) Challenges of Regulatory Coordination in Asia between Hong Kong and Singapore

Despite Hong Kong's pioneering establishment of a stablecoin licensing system, the Monetary Authority of Singapore (MAS) simultaneously launched a "stablecoin sandbox" that allows for the experimental issuance of tokens pegged to existing fiat currencies. Regulatory arbitrage between the two regions may lead to issuers engaging in "regulatory site selection" behavior, which necessitates the establishment of unified reserve audit standards and anti-money laundering information sharing mechanisms through the ASEAN Financial Regulatory Forum.

Although Hong Kong and Singapore have similar goals in their stablecoin regulatory policies, their implementation paths show significant differences. Hong Kong adopts a prudent tightening regulatory approach, with the Monetary Authority planning to establish a legal stablecoin licensing system, positioning stablecoins as "virtual bank substitutes" and strictly adhering to traditional financial regulatory frameworks. In contrast, Singapore maintains an experimental regulatory concept, allowing innovative pilots that link digital tokens to fiat currencies, reserving flexible space for technological and business model innovation, and overall adopting a regulatory attitude of tolerance for errors and experimentation.

This regulatory divergence may lead issuing institutions to selectively register to evade strict scrutiny or to exploit differences in regulatory standards for arbitrage operations, thereby undermining the effectiveness of the review of fiat currency pegging mechanisms. In the long term, if there is a lack of coordination, this divergence may compromise regulatory fairness and policy consistency, and even trigger regional regulatory competition risks, causing the two regions to fall into a competitive internal struggle. Furthermore, the inconsistency of regulatory standards may weaken Asia's voice in the global stablecoin system, consequently affecting the competitiveness of Hong Kong and Singapore as international financial centers.

Regulatory agencies in both regions need to strengthen policy coordination, seeking a better balance between preventing systemic risks and encouraging financial innovation, in order to enhance Asia's overall influence in global digital financial governance.

Conclusion: Regulatory Clarity Opens a Golden Decade for Stablecoins

The joint implementation of the US GENIUS Act and the Hong Kong regulatory draft marks a shift in digital asset regulation from fragmentation to systematization. Compliant USD stablecoins are expected to achieve a magnitude of rise within ten years, becoming the core bridge connecting traditional finance with the crypto ecosystem. The technological evolution of public chain infrastructure will determine whether it can capture the maximized value dividend within the regulatory framework. For issuers, building a multi-chain, multi-currency, and multi-regulatory compliant stablecoin system will be the key strategy to win the competition in the next decade.