China Stablecoin Regulation: Hong Kong Licensing Vs Mainland Guardrails


China Stablecoin Regulation: Hong Kong Licensing Vs Mainland Guardrails


In July, the United States set a global benchmark for digital dollars with the passage of the GENIUS Act, the first federal framework for stablecoins. With this bill, Washington confirmed that dollar-backed tokens will underpin digital settlement.

The move has intensified debate in Asia. China faces a dilemma: promoting yuan use while preserving strict capital controls. Hong Kong offers a compromise through its new licensing regime, which took effect on August 1.

Hong Kong Opens While Mainland China Tightens

The Hong Kong Monetary Authority requires issuers to hold HK$25 million in capital, maintain segregated liquid reserves, and follow anti-money-laundering standards. No licenses have been granted yet.

On the mainland, the People’s Bank of China reiterated that digital yuan pilots remain its priority. Beijing has cracked down on Tether-linked transfers and banned firms from holding crypto directly, limiting exposure to offshore subsidiaries or Hong Kong-listed products.

“The broader challenge… is the conservative culture of its finance industry.” Emil Chan, Hong Kong Digital Finance Association, said in a CNN interview.

Tokenization and Infrastructure Push

Hong Kong has paired stablecoin rules with broader tokenization efforts. On August 7, regulators launched the world’s first real-world asset (RWA) registry to standardize data and valuations. Officials are also consulting on custody and OTC rules.

“It puts Hong Kong ahead of almost any other Asian jurisdiction… It’s going to be a blueprint for others.” — Yat Siu, Animoca Brands, in CNN.

Private activity reflects the momentum. HSBC has rolled out blockchain settlement for trade finance, while China Asset Management (Hong Kong) introduced Asia’s first tokenized retail money market fund. Tokenized gold and green bonds add to the ecosystem.

Net inflows of stablecoins to China in 2024 |The Economist

Analysts say yuan-backed stablecoins remain unlikely. Offshore CNH deposits total under 1 trillion yuan, versus more than 300 trillion onshore, leaving reserves too thin for large issuers. Pegs to the Hong Kong dollar or US dollar are more viable.

Dollar-linked stablecoins already absorb vast amounts of US Treasuries. HKD-backed tokens would also tie demand to the city’s dollar peg, paradoxically strengthening the greenback.

Regional Competition For Stablecoin Edge

Hong Kong’s cautious openness contrasts with Beijing’s ban-and-control approach. Early stablecoin licenses are expected to go to major banks and tech groups, with first approvals targeted by year-end.

Regional voices are calling for a multi-currency stablecoin alliance, led by Singapore and the UAE, to reduce reliance on the dollar and boost cross-border liquidity.

For now, Hong Kong’s licensing regime and tokenization drive put it ahead of Asian rivals.

However, high compliance costs and conservative finance culture may slow adoption, leaving USD-pegged tokens dominant in the region.

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