Comparative analysis of the stablecoin legislation in Hong Kong and the United States, how does it affect the global Web3 ecosystem?

The recent simultaneous advancement of stablecoin regulatory legislation in the United States and Hong Kong heralds a wave of global compliance. This article provides an in-depth analysis of the regulatory differences, macroeconomic impacts, and far-reaching implications for the Web3 ecosystem. This article is derived from an article written by OKG Research and was compiled, compiled and contributed by wublockchain. (Synopsis: Stablecoins have been tempered for 10 years and finally become digital cash representatives endorsed by the US government) (Background supplement: Crypto mom Hester Peirce: Securities law should be clear on the jurisdiction of cryptocurrencies!) Stablecoins, memes and NFTs are not securities) The US Senate and Hong Kong Legislative Council have taken key steps on stablecoin regulation almost "back and forth" this week: the former overwhelmingly passed a procedural motion of the GENIUS Act, clearing the way for the first federal stablecoin bill in the United States; The latter passed the third reading of the Stablecoin Bill, making Hong Kong the first jurisdiction in the Asia-Pacific region to establish a stablecoin licensing regime. The high overlap of the legislative rhythms of the East and the West is not only a collision of chances, but also a competition for the right to speak about financial discourse in the future. Annual stablecoin trading volume may exceed $100 trillion in 2030 According to incomplete statistics from OKG Research, the current global stablecoin market value is close to $250 billion, an increase of more than 22 times in the past 5 years; Year-to-date 2025, on-chain transaction volume has exceeded $3.7 trillion, and is expected to approach $10 trillion for the full year. US dollar stablecoins represented by USDT and USDC have been widely used in emerging markets for transaction remittances, and in some regions even exceed the scale of traditional payment systems. Stablecoins have leapt from edge assets to key nodes in the competition between global payment networks and sovereignty, and the United States and Hong Kong have accelerated legislation almost simultaneously, which means that the global stablecoin market has entered a period of accelerated compliance. Based on this, OKG Research refers to Standard Chartered Bank's previous calculation model, combined with the current regulatory signal release rhythm and institutional capital attitude, and under the premise of keeping the current weekly conversion rate of stablecoins basically unchanged, it calculates: Under the optimistic scenario of the gradual rollout of the global compliance framework and the widespread adoption by institutions and individuals, the global stablecoin market supply will reach $3 trillion in 2030, the monthly on-chain transaction volume will reach $9 trillion, and the total annual transaction volume may exceed $100 trillion. This means that stablecoins will not only compete with traditional electronic payment systems, but will also occupy a structurally fundamental position in the global clearing network. In terms of market capitalization, stablecoins will become the "fourth type of base currency assets" after government bonds, cash, and bank deposits, and become an important medium for digital payments and asset circulation. What is more noteworthy is that under this growth trend, the reserve structure of stablecoins will also have a feedback effect on the macro economy. OKG Research has previously launched that the stablecoin's current size absorbs about 3% of maturing short-term U.S. bonds, ranking 19th in the list of overseas U.S. debt holders. Considering that the GENIUS Act explicitly requires 100% of highly liquid dollar assets as reserves, short-term U.S. Treasuries are seen as the primary option (more than 80% of USDT/USDC reserve assets are currently tied to U.S. Treasuries.) At a 50% allocation, a $3 trillion market cap would correspond to at least $1.5 trillion in short-term Treasury demand. This size is close to the current US bond holdings of overseas sovereign buyers in China or Japan, and stablecoins are expected to become the "biggest hidden creditors" of US finances. Comparison of US-Hong Kong Stablecoin Regulatory Frameworks: Consensus in Divergence Although the United States and Hong Kong differ in their legislative paths and some details, they have reached a high degree of consensus on the basic principles of "legal currency anchoring, sufficient reserves, and licensed issuance". The GENIUS Act restricts "payment stablecoins", that is, stablecoins that are anchored to fiat currencies such as the US dollar, promise 1:1 returnability, and do not carry interest income, emphasizing their non-security properties, and are intended to prevent stablecoins from evolving into financial products with investment properties. Hong Kong, on the premise of ensuring a 1:1 full anchorage, has not restricted interest income and anchor structure, seeking to open up a new track in the dollar-dominated stablecoin market and reserve space for future innovation. In terms of reserve requirements, both the United States and Hong Kong require sufficient anchoring of highly liquid assets, but the GENIUS Act clearly defines the types of qualified reserve assets, including T-Bills, cash and repurchase agreements, etc., and requires monthly audits; Hong Kong also requires audit and segregated custody, but the types of reserve assets are not fully limited. In terms of institutional structure, the GENIUS Act adopts a "federal-state" dual-track system, providing three paths for stablecoin issuance: banks or their subsidiaries apply for stablecoin issuance, which are regulated by banking regulators such as the US Federal Reserve and FDIC; Non-banks can apply to the OCC to become a federal licensed issuer or obtain a license through a state regulator. In Hong Kong, the HKMA is uniformly licensed and requires permission to be applied for as long as it is anchored to Hong Kong dollars or actively provides services to the Hong Kong public, regardless of whether the stablecoin issuer is based in Hong Kong or not. In terms of the management of overseas issuers, the GENIUS Act explicitly prohibits the circulation of unlicensed overseas stablecoins in the US market, authorizes the Treasury Department to establish a "non-compliant stablecoin list", and blocks their circulation path through US digital asset service providers; Hong Kong, on the other hand, mainly focuses on stablecoins anchored to the Hong Kong dollar, and remains open to non-Hong Kong dollar stablecoins. Behind these institutional differences, it reflects the different demands of the two places in the positioning of stablecoins. The United States mainly maintains the dominance of the US dollar and serves the structural financing needs of finance, and promotes stablecoins to become an extended form of on-chain US dollars; Hong Kong, on the other hand, hopes to attract global Web3 projects without compromising local financial stability, leaving room for policy flexibility in many details, aiming to create a controlled but open and compatible Asia-Pacific compliance innovation testing ground. How does the implementation of stablecoin regulation affect the Web3 ecosystem? The real significance of stablecoin regulation is to provide a payment and settlement foundation for the mass adoption of Web3. In the field of DeFi, although stablecoins such as USDT and USDC have become important settlement assets for on-chain financial innovation, they lack a clear legal status and accountability mechanism, making it difficult for institutions to directly participate. If stablecoin regulatory frameworks such as the Genius Act land one after another, stablecoins provided by compliant issuers will become the clearing core of "compliant DeFi", protocols will embed more KYC, AML and asset identification modules, and decentralized finance will gradually evolve into an "auditable on-chain financial network". In the Web3 payment system, the implementation of stablecoin supervision will break the gray boundary between the past payment scenario and asset circulation, making stablecoins truly move from "transaction intermediaries" to "payment channels". OKG Research has observed that since Visa announced that the cumulative stablecoin clearing volume exceeded $225 million, several payment technology companies have successively embedded stablecoins into their merchant settlement processes; Web3 wallets use stablecoins as default payment assets to expand micropayment scenarios such as deposits, tips, and subscriptions. On-chain payments are transforming from a "crypto in-circle transfer tool" to an "enterprise-level financial interface", and compliance is a necessary prerequisite for this transformation. The deeper change lies in the reshaping of the global clearing structure: stablecoins anchor fiat currencies in a 1:1 way, opening up the connection between local currencies and on-chain assets, while not relying on the bank account system, can achieve "peer-to-peer" clearing, which means that cross-border payments, on-chain trade finance, RWA dividends, etc. in the future...