IPP文摘｜稳定币的全球角力：监管多样性与核心原则

Core Viewpoint - Stablecoins have evolved from an emerging concept to a key force reshaping the financial landscape, leading to intensified global competition and diverse regulatory approaches across countries [2] Regulatory Landscape - The global regulatory landscape for stablecoins is characterized by significant diversity, with some countries banning their use while others embrace them as part of a regulatory sandbox [2] - The U.S. Senate passed the "Genius Act" on June 17, 2025, promoting compliance for USD stablecoins to reinforce dollar dominance and alleviate U.S. debt crises [2] - Hong Kong's Legislative Council passed the "Stablecoin Bill" on May 21, 2025, to regulate stablecoins within a structured framework [2] Key Regulatory Principles - Emphasis on 1:1 reserves and high liquidity, requiring stablecoin issuers to hold sufficient, high-quality, and liquid reserve assets to ensure value stability and redemption capability [4] - Strengthened prudential regulation of issuers, imposing stricter licensing, capital, governance, and risk management requirements [5][6] - Enhanced transparency and audit requirements, mandating regular disclosure of reserve asset composition and independent audits [7][8] - Focus on consumer protection and anti-money laundering/anti-terrorism financing obligations, placing user asset safety and rights at the core of regulation [9][10] - Cautious stance towards specific types of stablecoins, such as algorithmic and endogenous collateralized stablecoins, with some jurisdictions considering outright bans [11] Regional Regulatory Models - The U.S. employs a dual-track regulatory model, with a national focus on reinforcing dollar supremacy through mandatory dollar asset reserves [13] - The EU's MiCA establishes a comprehensive regulatory framework for stablecoins, effective from June 30, 2024, requiring issuers to meet strict obligations [18] - Hong Kong's regulatory framework emphasizes principle-based legislation followed by detailed enforcement, allowing for dynamic adjustments [19] - Singapore's regulatory approach features "labeling" for high-standard stablecoins, with strict asset reserve requirements [23] - Japan adopts a cautious innovation model, allowing trust companies to issue stablecoins while gradually relaxing reserve asset management requirements [24] - The UK follows the principle of "same risk, same regulatory outcome," ensuring stablecoins in systemic payment systems are subject to equivalent standards as commercial banks [26] Global Trends - The global trend towards stablecoin regulation has accelerated since 2025, with various countries implementing or planning regulatory frameworks [27]