Overview of Global Stablecoin Regulatory Dynamics

In recent years, the rapid development of stablecoins in the cryptocurrency field has attracted significant attention from global regulatory bodies. As a type of digital currency pegged to fiat currencies or other assets, stablecoins are widely used in areas such as cross-border payments and decentralized finance due to their value stability. Especially in the current market cycle, the tokenization of real-world assets (RWA) has performed remarkably well, attracting active participation from traditional financial institutions and Web3 native organizations, leading to an increasing number of investors focusing on this emerging sector.

As the stablecoin market continues to expand, governments and international organizations around the world have begun to introduce relevant policies to regulate and supervise the development of stablecoins. This article will briefly outline the current regulatory dynamics of stablecoins in major regions globally.

United States

As one of the main markets for stablecoin development, the regulatory policies in the United States are quite complex, involving multiple regulatory agencies. The Securities and Exchange Commission (SEC) may classify certain stablecoins as securities, requiring them to comply with relevant provisions of the Securities Act. The Office of the Comptroller of the Currency (OCC) has proposed allowing national banks and federal savings associations to provide services to stablecoin issuers, but they must strictly adhere to anti-money laundering and compliance requirements. Currently, the U.S. Congress is discussing legislative proposals such as the Stablecoin Transparency Act, aimed at establishing a unified regulatory framework for stablecoins.

European Union

The EU's stablecoin regulation is primarily based on the Markets in Crypto-Assets Regulation (MiCA). MiCA categorizes stablecoins into Asset-Referenced Tokens (ART) and Electronic Money Tokens (EMT) and establishes corresponding regulatory requirements. Entities issuing stablecoins must obtain licenses from EU member states and meet specific requirements such as capital reserves and transparency disclosures.

Hong Kong

The Hong Kong Monetary Authority released the main content of the stablecoin regulatory framework in July 2024. The framework requires companies issuing or promoting fiat stablecoins to the public in Hong Kong to obtain a license from the Monetary Authority. Regulatory requirements cover various aspects including reserve asset management, corporate governance, risk control, information disclosure, and anti-money laundering. In addition, Hong Kong has also launched a "sandbox" program for stablecoin issuers to facilitate communication between regulators and the industry. Recently, the Hong Kong government announced the draft "Stablecoin Ordinance" aimed at further improving the regulatory framework for virtual asset activities.

Singapore

Singapore regards stablecoins as digital payment tokens under the Payment Services Act. The issuance and circulation of stablecoins require permission from the Monetary Authority of Singapore (MAS). MAS also provides a regulatory sandbox for startups to test innovative business models related to stablecoins.

Japan

Japan revised the Payment Services Act in 2022, establishing a regulatory framework for stablecoins. Stablecoins fully backed by fiat currency are defined as "electronic payment instruments" (EPI). Only three types of institutions—banks, fund transfer service providers, and trust companies—can issue stablecoins. Institutions wishing to engage in stablecoin-related business must register as electronic payment instrument service providers (EPISP).

Brazil

The Central Bank of Brazil plans to regulate stablecoins and asset tokenization in 2025. In November 2024, the Central Bank proposed a regulatory plan that suggests limiting users from withdrawing stablecoins from centralized exchanges to self-custody wallets. However, this restriction may be lifted if key issues such as transaction transparency are improved.

Conclusion

Regulatory attitudes towards stablecoins around the world are gradually becoming clearer. Whether it is establishing regulatory sandboxes or formulating rules based on the different characteristics of stablecoins, more targeted regulatory policies are expected to be introduced in the future. The cross-border payment sector is likely to become one of the most widely applied scenarios for stablecoins. With the improvement of the regulatory framework, the stablecoin market is expected to achieve more standardized and healthy development.