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New Global Regulatory Landscape for Stablecoins: The US GENIUS Act and Hong Kong Regulations Leading Market Development
Market Outlook and Development Trends under the New Regulatory Landscape for Stablecoins
The global digital asset market is entering a new growth cycle driven by regulation. The stablecoin legislation introduced successively by the United States and Hong Kong not only fills the regulatory gap but also provides a clear compliance framework for the market. These regulations cover aspects such as reserve asset segregation, redemption guarantees, and anti-money laundering compliance, effectively reducing systemic risk.
The Impact of the U.S. GENIUS Act
The GENIUS Act, passed by the U.S. Senate in May 2025, establishes a detailed regulatory framework for stablecoin issuers. The Act requires stablecoin issuers to hold a reserve of high liquid assets at a minimum ratio of 1:1, undergo regular audits, and comply with anti-money laundering and know-your-customer requirements. The Act also prohibits stablecoins from offering interest yields, restricts foreign issuers from entering the U.S. market, and clarifies the legal status of stablecoins.
The implementation of this bill is expected to profoundly impact the global cryptocurrency market landscape. It will promote stablecoins as an important channel for distributing U.S. Treasury bonds, alleviating pressure on the U.S. Treasury while strengthening the dollar's position in international settlements. A clear regulatory framework may attract more institutions into the stablecoin sector, fostering innovation in payment systems. However, the bill has also sparked some controversies, such as potential conflicts of interest and issues with international regulatory coordination.
It is predicted that under clear regulations, the global stablecoin market value is expected to grow from $230 billion in 2025 to $1.6 trillion by 2030. This forecast is based on two assumptions: compliant stablecoins will accelerate the replacement of traditional cross-border payment channels, saving a substantial amount in international remittance costs each year; the locked volume of stablecoins in DeFi protocols will increase significantly, becoming the foundational liquidity layer of decentralized finance.
Hong Kong Stablecoin Regulatory Framework
The recent stablecoin regulations issued by the Hong Kong SAR government establish a licensing system that requires issuers to obtain permission from the financial authority and meet strict reserve asset management, redemption mechanism, and risk control requirements. Hong Kong also plans to introduce a dual licensing system for over-the-counter trading and custody services in the future to enhance the comprehensive regulation of virtual assets.
The Hong Kong Monetary Authority plans to release operational guidelines on the tokenization of real-world assets in 2025, promoting the on-chain tokenization process of traditional assets. Through smart contract technology, functions such as automatic dividends and interest distribution will be realized, as Hong Kong is committed to building an innovative ecosystem that integrates traditional finance and blockchain technology.
Comparison of Regulatory Frameworks for Stablecoins in the US and Hong Kong
Although Hong Kong's regulatory framework draws on the logic of the United States, there are significant differences in the implementation details. These differences involve multiple aspects such as issuance access, reserve assets, cross-border operations, and regulatory agencies.
Evolution of Global Stablecoin Landscape
global reserve currency effect of the US dollar stablecoin
The GENIUS Act requires payment stablecoins to use U.S. Treasury bonds as reserve assets, which gives U.S. dollar stablecoins strategic significance beyond the realm of digital currencies. It becomes a new distribution channel for U.S. Treasury bonds, constructing a global capital circulation system. From the perspective of international settlement, stablecoins represent a paradigm shift in the U.S. dollar clearing system, expanding the international use cases of the dollar and consolidating its core position in the global monetary system.
Asia regulatory coordination challenges
Although Hong Kong and Singapore have similar objectives regarding stablecoin regulatory policies, their implementation paths differ. Hong Kong adopts a prudently tightening regulatory approach, while Singapore adheres to an experimental regulatory philosophy. This difference may lead to selective registration or regulatory arbitrage by issuing institutions, affecting the effectiveness of the review of fiat currency pegging mechanisms. In the long run, the lack of coordination may undermine regulatory fairness and policy consistency, weakening Asia's voice in the global stablecoin system.
Outlook
The implementation of the U.S. GENIUS Act and the Hong Kong Ordinance Draft marks the transition of digital asset regulation from fragmentation to systematization. Compliant USD stablecoin is expected to see significant growth in the next decade, becoming a core bridge connecting traditional finance and the crypto ecosystem. The technological evolution of public chain infrastructure will determine whether it can maximize value within the regulatory framework. For issuers, building a multi-chain, multi-coin, and multi-regulatory compatible stablecoin system will be the key strategy to win future competition.