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科普|稳定币为何成为全球立法焦点?一文读懂监管逻辑与制度博弈
Xin Lang Cai Jing· 2025-07-31 23:49
Core Viewpoint - Stablecoins, once a gray area in the blockchain world, are now being actively integrated into regulatory frameworks by governments worldwide, indicating a shift towards a new order in global digital finance [1] Group 1: Definition and Importance of Stablecoins - Stablecoins are digital currencies that anchor their value to fiat currencies (e.g., USD, HKD, EUR), providing price stability and programmability, serving as a crucial bridge between traditional finance and the Web3 world [2] - As of May 2025, the global market capitalization of stablecoins is projected to reach approximately $245.8 billion, reflecting a year-on-year growth of about 53%, with monthly stablecoin transaction volumes expected to exceed $3.7 trillion, a growth of over 150% from the previous year [2] Group 2: Need for Regulation - The rapid expansion of stablecoins has revealed several risks, such as insufficient reserve transparency and stability mechanisms, prompting global regulatory bodies to intervene [3] - Issues like the lack of transparency in reserves (e.g., USDT's undisclosed asset backing) and the failure of algorithmic mechanisms (e.g., Terra UST's collapse) highlight the necessity for clear regulatory boundaries and legal frameworks [3] - The IMF has warned that unregulated stablecoins could threaten monetary sovereignty and has recommended the establishment of unified standards to address their cross-border impacts [3] Group 3: Global Regulatory Approaches - Major economies are accelerating the establishment of stablecoin regulatory frameworks, with the EU leading by passing the MiCA regulation, categorizing stablecoins as electronic money tokens (EMT) and implementing a unified licensing system [4] - The US is proposing the GENIUS Act and state-level regulations that include a ban on unlicensed issuances and a requirement for 100% reserves [4] - Hong Kong's recently implemented Stablecoin Regulation adopts a dual-track model of licensing and sandboxing, setting a compliance benchmark globally [4] Group 4: Highlights of Hong Kong's Regulatory Model - The "licensing system" principle in Hong Kong mandates that any entity wishing to issue or circulate stablecoins must obtain a license from the HKMA, effectively curbing unauthorized issuances and associated risks [5] - Key regulatory standards include a minimum capital requirement of HKD 25 million, 100% asset backing for all stablecoins, prohibition of interest payments to users, regular audits, and compliance with AML and KYC standards [6][7] Group 5: Political and Financial Implications of Stablecoin Legislation - The legislative process surrounding stablecoins reflects deeper geopolitical and financial dynamics, including the competition between digital currencies and national sovereign currencies [9] - The control over cross-border payment channels and the establishment of who can legally issue stablecoins are central to the ongoing power struggle in the financial landscape [9] - Stablecoins are not just a form of currency but are also reshaping the foundational infrastructure of global finance, influencing the future of asset circulation [9] Group 6: Future Trends in Stablecoin Regulation - The potential for a unified international regulatory standard is a focal point for regulators and policymakers, with institutions like the BIS and FSB advocating for coordinated frameworks [10] - The emergence of a "stablecoin rating" system by third parties or official bodies may help users identify quality stablecoins [10] - The relationship between stablecoins and central bank digital currencies (CBDCs) is becoming increasingly intertwined, with some countries exploring parallel mechanisms [10]