The East and West Compete for the Discourse Power of Stablecoins: The Legislative Wave in the US and Hong Kong Reshapes the New Global Financial Order

The U.S. Senate and the Hong Kong Legislative Council took key steps in stablecoin regulation this week, almost in sync: the former overwhelmingly passed a procedural motion for the GENIUS Act, clearing the way for the first federal stablecoin bill in the U.S.; the latter passed the Stablecoin Regulation Draft in its third reading, making Hong Kong the first jurisdiction in the Asia-Pacific region to establish a stablecoin licensing system. The high degree of alignment in legislative rhythms between the East and West is not just a coincidence of timing, but a competition for future financial discourse power.

The annual trading volume of stablecoins is expected to exceed 1 trillion USD by 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 five years; Year-to-date 2025, on-chain trading volume has exceeded $3.7 trillion and is expected to approach $10 trillion for the full year. U.S. dollar stablecoins, represented by USDT and USDC, have been widely used for transaction remittances in emerging markets, and in some regions, they even exceed the scale of traditional payment systems. Stablecoins have jumped from marginal assets to key nodes in global payment network and sovereign competition, 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 referenced the previous calculation model of Standard Chartered Bank and combined it with the current regulatory signal release rhythm and institutional capital attitude. It was calculated that, while keeping the current stablecoin turnover rate basically unchanged:

**Under the optimistic scenario of the gradual roll-out of global compliance frameworks and widespread adoption by institutions and individuals, the global stable currency market supply will reach US$3 trillion by 2030, with monthly on-chain trading volume reaching US$9 trillion and annual total trading volume likely to exceed US$10 trillion. This means that stablecoins will not only compete with traditional electronic payment systems, but will also occupy a structural and fundamental position in the global clearing network. In terms of market capitalization, stablecoins will become the "fourth type of base monetary assets" after treasury bonds, cash, and bank deposits, and become an important medium for digital payment 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 macroeconomy. OKG Research previously released that the existing scale of stablecoins has absorbed about 3% of the upcoming short-term U.S. Treasury bonds, ranking 19th among overseas U.S. Treasury bond holders.

Considering that the GENIUS Act clearly requires 100% of reserves to be backed by highly liquid US dollar assets, short-term US Treasury bonds are viewed as the primary option (currently, over 80% of USDT/USDC reserve assets are related to US Treasury bonds.) If estimated with a 50% allocation ratio, a market value of 3 trillion dollars would correspond to at least 1.5 trillion dollars in short-term US Treasury bond demand. This scale is already close to the current US Treasury bond holdings of overseas sovereign buyers from China or Japan, and stablecoins are expected to become the "largest invisible creditor" of the US Treasury.

Comparison of Regulatory Frameworks for USDT and Stablecoins: Consensus Amid Disagreements

Although the United States and Hong Kong have differences in legislative paths and some details, they have reached a high level of consensus on fundamental principles such as "fiat currency anchoring, sufficient reserves, and licensed issuance."

The GENIUS Act defines "payment-type stablecoins," which are stablecoins pegged to fiat currencies such as the US dollar, committed to a 1:1 redeemable rate, and must not carry interest earnings, emphasizing their non-securities nature to prevent them from evolving into investment-type financial products. In contrast, Hong Kong has not yet restricted interest earnings and pegging structures while ensuring a 1:1 full peg, seeking to carve out a new niche in the US dollar-dominated stablecoin market and reserving space for future innovations.

In terms of reserve requirements, both the US and Hong Kong require sufficient anchoring of high liquidity assets, but the GENIUS Act explicitly specifies the types of qualified reserve assets, including T-Bills, cash, and repurchase agreements, and requires monthly audits; Hong Kong also requires audits and segregated custody, but the types of reserve assets are not fully specified.

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 the issuance of stablecoins, which are supervised by banking regulators such as the Federal Reserve and the FDIC; Non-bank institutions can apply to the OCC to become federally licensed issuers or obtain a license through a state regulator**. In Hong Kong, the HKMA is licensed by the HKMA and requires a licence to apply for a licence as long as the stablecoin issuer is anchored to the Hong Kong dollar or actively provides services to the Hong Kong public, regardless of whether the stablecoin issuer is based in Hong Kong.

In terms of managing overseas issuers, the GENIUS Act explicitly prohibits unlicensed overseas stablecoins from circulating in the U.S. market, authorizing the Treasury to establish a "non-compliant stablecoin list" and blocking their circulation path through U.S. digital asset service providers; Hong Kong, on the other hand, mainly focuses on stablecoins pegged to the Hong Kong dollar, while remaining open to non-HKD stablecoins.

The differences behind these systems reflect the different demands for stablecoin positioning in the two regions. The United States mainly aims to maintain the dominance of the dollar and serve the structural financing needs of its fiscal system, promoting stablecoins as an extension of the on-chain dollar; while Hong Kong hopes to attract global Web3 projects without compromising local financial stability, leaving room for policy flexibility in many details, aiming to create a controlled yet open and compatible compliance innovation testing ground in the Asia-Pacific region.

How will stablecoin regulation impact the Web3 ecosystem?

The true significance of stablecoin regulation is to provide the foundation for payments and settlements for the large-scale adoption of Web3.

In the DeFi space, although stablecoins like USDT and USDC have become important settlement assets for on-chain financial innovations, the lack of clear legal status and accountability mechanisms makes it difficult for institutions to participate directly. If regulatory frameworks for stablecoins, such as the Genius Act, are implemented, stablecoins issued by compliant issuers will become the clearing core of "compliant DeFi," with protocols embedding more KYC, AML, and asset identification modules. 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 payment scenarios and asset circulation in the past, making stablecoins truly move from "transaction intermediary" to "payment channel". OKG Research observed that since Visa announced that its cumulative stablecoin settlement volume exceeded $225 million, a number of payment technology companies have successively embedded stablecoins into their merchant settlement processes, while Web3 wallets have used stablecoins as the default payment asset to expand micropayment scenarios such as recharge, tipping, and subscription. On-chain payments are changing from "crypto-circle transfer tools" to "enterprise-level financial interfaces", and compliance is a necessary prerequisite for this transformation.

The deeper change lies in the reshaping of the global settlement structure: stablecoins, anchored to fiat currency at a 1:1 ratio, bridge the connection between local currency and on-chain assets, while not relying on the banking account system, allowing for "peer-to-peer" settlement. This means that in the future, in scenarios such as cross-border payments, on-chain trade financing, and RWA dividends, stablecoins may replace traditional banks as the central hub for the flow of funds.

In the past, we discussed the large-scale adoption of Web3, focusing too much on technological breakthroughs and user experience, while neglecting the legitimacy of underlying assets. Now, compliant stablecoins provide the "last piece of the puzzle": they are recognized trading assets under the system and possess programmability for on-chain circulation. They are both digital mirrors of the US dollar and Hong Kong dollar, and can be directly utilized in DeFi protocols and NFT transactions.

In other words, stablecoins are not an accessory to Web3, but one of the driving forces pushing it towards the mainstream. With the support of compliant stablecoins, from RWA asset trading to on-chain salary payments, from cross-border settlement to Web3 payment interfaces, stablecoins will become the "infrastructure asset" that drives the large-scale adoption of the on-chain economy.