Stablecoins, as a key element in the convergence of blockchain and finance, have attracted global attention in terms of regulatory frameworks. Hong Kong and the United States have distinctive regulatory approaches in asset reserves, risk control, and innovation. Based on a recent Space discussion, this article compiles insights from Rita Liu (CEO of Yuan Coin Technology), Paolo Chen (Ecological Partner at Victory Securities), Lin Junxie (Web3 Partner at Huaying Securities), Shao Jiading (Partner at Mankun Law Firm), and Wu Chen (Co-founder of EX.IO), analyzing the regulatory differences and future trends between the two regions.

Rita Liu points out that Hong Kong's "Fiat Stablecoin Regulatory Act" has entered the licensing stage, leading globally. Hong Kong demonstrates three key characteristics in reserve assets: first, no restriction on anchor currencies, allowing multi-currency pegging such as US dollar, Euro, and offshore RMB, differing from Singapore's single currency limitation; second, reserve assets must be low-risk, high-liquidity assets, including bank deposits, bonds issued by regulated institutions, and their tokenized forms (like tokenized US Treasury bonds); third, explicitly accepting Real World Assets (RWA), reflecting support for blockchain innovation. Additionally, Hong Kong sets a 25 million HKD capital threshold (with exemptions for bank-type institutions), requiring issuers to establish local CEO, alternate CEO, and stablecoin manager, all of whom must be Hong Kong residents, ensuring localized regulation. Rita emphasizes that Hong Kong prohibits algorithmic stablecoins, focusing on fiat stablecoins as payment tools and banning interest payments to token holders. She is optimistic about Hong Kong promoting financial integration through RWA and multi-currency issuance, anticipating stablecoins will reshape cross-border settlement systems in "third-generation payments" by combining public chains (like Ethereum) and cross-chain technologies for efficient peer-to-peer payments.

Paolo Chen states that Victory Securities, as the most active virtual asset broker in Hong Kong with the highest local trading volume, is incubating a compliant licensed exchange platform. In the stablecoin and RWA domain, Victory Securities collaborates with Xunying Group and Ant International to launch an RWA project based on new energy battery exchange, exploring on-chain applications. He believes Hong Kong's regulatory framework, by supporting RWA and multi-currency pegging, demonstrates an open attitude towards the Web3 ecosystem, while the US stablecoin bill is more strategically motivated to maintain the dollar's status. Regarding algorithmic stablecoins, Paolo cites Luna/UST's "death spiral" to highlight their lack of adequate liquidity and risk-resistant collateral assets, which can easily trigger systemic risk spillover. Therefore, mainstream jurisdictions like Hong Kong prohibit algorithmic stablecoins, prioritizing financial stability.

Lin Junxie shares that Huaying Securities, an early mover in virtual assets in Hong Kong, collaborated with Huaxia Fund and Standard Chartered Bank to issue Hong Kong's first tokenized monetary fund product, viewed as a crucial attempt in local stablecoin development. The product plans to apply to scenarios like repurchase transactions, paving the way for stablecoin applications in payment and financial instruments. He believes Hong Kong, with its linked exchange rate system and financial reserves, is suitable for multi-currency stablecoin issuance, especially with huge potential in cross-border trade scenarios. In contrast, fragmented state-level regulation in the US limits stablecoin cross-border expansion. Lin Junxie notes that while stablecoins may diminish traditional banks' payment functions, core businesses like lending remain difficult to replace, and future exploration is needed on how to incorporate crypto-asset collateralized stablecoins into regulation.

Lawyer Shao Jiading adds that Hong Kong's stablecoin regulations are more detailed in capital requirements, personnel configuration, and retail sales norms, making them more operational compared to the US bill still in draft stage. For instance, Hong Kong requires issuers to establish local management teams, with only licensed issuers permitted to sell stablecoins to retail users or conduct advertising. Regarding algorithmic stablecoins, Shao notes that major jurisdictions including Hong Kong, EU, Singapore, Japan, and the US generally prohibit them, due to the Luna/UST event exposing their "death spiral" risks during market volatility, failing to meet high liquidity and low-risk regulatory requirements. For interest-bearing stablecoins, Hong Kong excludes them from the fiat stablecoin framework, placing them under banking or securities law regulation, demonstrating regulatory clarity.

Wu Chen analyzes the proposed US "Genius Stablecoin Act", which sets a $10 billion threshold and a two-tier regulation that might pave the way for tech giants like Twitter and Google to issue stablecoins. If the bill passes, small issuers will face more lenient regulation, but large enterprises' coin issuance could trigger redemption risks similar to the 2008 financial crisis. He points out that US regulatory fragmentation (between federal and state levels) creates arbitrage opportunities, limiting stablecoin expansion in cross-border scenarios. Considering Hong Kong's licensed Virtual Asset Trading Platform (VATP) role, Wu Chen believes inconsistent regulation will hinder tech companies' stablecoin scalable development, making it difficult to replace traditional bank functions in the short term.

Rita Liu further proposes that the stablecoin market should "bloom in hundred flowers" to meet massive cross-border payment demands. She categorizes payment systems into three generations: the first relying on SWIFT and intermediary banks; the second accelerating settlement through Fintech fund pool matching; the third centered on stablecoins, central bank digital currencies, and tokenized deposits, constructing an efficient cross-border payment network. Hong Kong's regulations do not restrict stablecoin currencies, with HKD, USD, and offshore RMB all eligible for compliant issuance. Rita reveals that Yuan Coin Technology prioritizes Ethereum for stablecoin issuance and is optimistic about multi-chain and cross-chain architectures in payment scenarios. She emphasizes that regulation will trend towards localization, with stablecoin projects serving Hong Kong requiring local licenses, and RWA on-chain will drive fund migration to blockchain.

Hong Kong and the US have different focuses in stablecoin regulation: Hong Kong attracts the Web3 ecosystem through flexible currency selection, RWA support, and high entry barriers; the US maintains market dominance through dollar advantages and strict disclosure. In risk control, Hong Kong emphasizes preventive measures, while the US relies on post-facto accountability; in innovation, Hong Kong promotes RWA and financial integration, and the US reinforces market position through technological iteration. In the future, stablecoins will play a greater role in cross-border payments and trade, and the convergence and competition of regulatory paths between the two regions will drive global financial digitization.