附表 美国、欧盟、中国香港稳定币监管框架对比

Core Points - The article discusses the regulatory frameworks for stablecoins in the United States, European Union, and Hong Kong, highlighting the definitions, issuing authorities, capital requirements, and asset backing for compliant stablecoins [1] Group 1: Regulatory Frameworks - The U.S. "GENIUS Act" defines compliant stablecoins as digital assets designed for payment or settlement, with issuance regulated by federal or state governments for those with a market cap under $10 billion [1] - The EU's "MiCA Act" defines compliant stablecoins as crypto assets referencing the value of a fiat currency, with oversight from appointed authorities in member states and reporting to the European Banking Authority (EBA) and the European Securities and Markets Authority (ESMA) [1] - Hong Kong's "Stablecoin Regulation" defines compliant stablecoins as digital representations of value, claiming to maintain stability by referencing one or more official currencies or other units designated by the Hong Kong Monetary Authority [1] Group 2: Issuing Authorities and Capital Requirements - In the U.S., issuing authorities for compliant stablecoins include federal or state governments, with no unified capital requirement, regulated based on size [1] - The EU requires issuers to have a minimum own funds of €125,000 and to meet the capital requirements of the Payment Services Directive (PSD2) [1] - Hong Kong mandates a minimum paid-up capital of HKD 25 million for recognized institutions issuing stablecoins [1] Group 3: Asset Backing and Management - All three regions require a 1:1 backing of stablecoins, with the U.S. allowing backing by cash or cash equivalents, and the EU and Hong Kong requiring safe, liquid, low-risk assets [1] - The U.S. requires at least 30% of reserves to be held in a separate account at a credit institution, while the EU and Hong Kong emphasize high liquidity and low-risk assets [1] - Regular audits and independent management of reserves are mandated in all three jurisdictions to ensure compliance and transparency [1]