In recent years, the rapid development of stablecoins has attracted the attention of regulatory agencies worldwide. Stablecoins, as a type of cryptocurrency pegged to fiat currencies or other assets, possess stable value characteristics and are widely used in cross-border payments, DeFi, and other fields. Particularly in this cycle, the performance of RWAs has been impressive, with both traditional financial investment institutions (like BlackRock) and web3-based organizations (like Sky, formerly Maker DAO) entering the field, and more and more investors are paying attention to this sector, gradually forming a trend of oscillating increases.
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https://defillama.com/stablecoins
"No rules, no boundaries," leading to various governments and international organizations starting to introduce policies to regulate stablecoins. This article provides a brief summary of the current regulatory dynamics.
United States (North America)
The United States is one of the main markets for stablecoin development, and its regulatory policies are quite complex. The stablecoin regulatory framework in the U.S. is primarily implemented by multiple agencies, including the Department of the Treasury, the Securities and Exchange Commission (SEC), and the Commodity Futures Trading Commission (CFTC).
For some stablecoins, the SEC may consider them to have securities attributes, requiring compliance with relevant provisions of the Securities Act. The Office of the Comptroller of the Currency (OCC), under the Department of the Treasury, previously proposed allowing national banks and federal savings associations to provide services to stablecoin issuers, but they must comply with anti-money laundering and compliance requirements. Recently, the U.S. Congress is discussing legislative proposals such as the Stablecoin Transparency Act, attempting to establish a unified regulatory framework for stablecoins. After the election of Donald Trump, known as the 'Crypto President,' although policies have not yet been introduced, the overall trend for crypto regulation seems to be positive.
European Union (Europe)
The stablecoin regulation in the EU mainly relies on the Regulation on Markets in Crypto Assets (MiCA).
MiCA classifies stablecoins into Asset-Referenced Tokens (ART) and Electronic Money Tokens (EMT). Electronic Money Tokens (EMTs) refer to tokens pegged to a single fiat currency, such as stablecoins pegged to the Euro or the US dollar. Asset-Referenced Tokens (ARTs) refer to tokens pegged to certain assets (such as fiat currencies, commodities, or crypto assets). MiCA establishes corresponding regulatory requirements. Entities issuing stablecoins must obtain permission from EU member states and meet requirements for capital reserves, transparency disclosures, and more.
Hong Kong (Asia)
On July 17, 2024, the Hong Kong Monetary Authority and the Financial Services and the Treasury Bureau jointly released a consultation summary introducing the main content of the upcoming stablecoin regulatory framework. According to this framework, companies wishing to issue or promote fiat stablecoins to the public in Hong Kong must first obtain a license from the Monetary Authority. This regulatory requirement includes the management of reserve assets, corporate governance, risk control, information disclosure, and measures against money laundering and terrorist financing.
Image source link:
https://www.hkma.gov.hk/gb_chi/news-and-media/press-releases/2024/07/20240717-3/?utm_source=chatgpt.com
Additionally, the Monetary Authority has launched a 'sandbox' program for stablecoin issuers to exchange views with the industry on the proposed regulatory requirements. The list of first participants was announced on July 18, 2024, including JD Coin Chain Technology (Hong Kong) Limited, Yuan Coin Innovation Technology Limited, and a consortium formed by Standard Chartered Bank (Hong Kong) Limited, Animoca Brands Limited, and Hong Kong Telecommunications Limited.
Image source link:
https://www.hkma.gov.hk/gb_chi/key-functions/international-financial-centre/stablecoin-issuers/?utm_source=chatgpt.com
Recently, on December 6, 2024, the government published the draft Stablecoin Regulation in the Gazette, aiming to introduce a regulatory framework for fiat stablecoin issuers in Hong Kong to improve the regulatory framework for virtual asset activities.
Singapore (Asia)
According to Singapore's Payment Services Act, stablecoins are considered a form of digital payment tokens, and their issuance and circulation require approval from the Monetary Authority of Singapore (MAS). MAS provides regulatory sandboxes for startups to test stablecoin-related business models.
Japan (Asia)
In June 2022, Japan revised the Payment Services Act (PSA) to establish a regulatory framework for the issuance and trading of stablecoins. According to the revised PSA, stablecoins that are fully backed by fiat currency are defined as 'Electronic Payment Instruments' (EPI), which can be used to pay for goods and services. There are specific requirements for issuing institutions: only three types of institutions can issue stablecoins: banks, money transfer service providers, and trust companies. Institutions wishing to engage in stablecoin-related business must first register as Electronic Payment Instrument Service Providers (EPISP) to obtain the necessary licenses to provide services.
Brazil (South America)
BCB President Roberto Campos Neto stated in October 2024 that they plan to regulate stablecoins and asset tokenization in 2025. In November 2024, BCB proposed a regulatory proposal suggesting a ban on users withdrawing stablecoins from centralized exchanges to self-custody wallets. It is reported that in December, the Deputy Head of BCB's Financial System indicated that if key issues such as transaction transparency could be improved, the central bank might lift the ban.
Summary
Additionally, the BRICS countries, including Russia, are considering using cryptocurrencies as a means of cross-border financing. Overall, whether it's setting up regulatory sandboxes for crypto companies or defining categories based on the different characteristics of stablecoins, an increasing number of stablecoin regulatory policies will be introduced in the future. Cross-border payments also seem to become one of the most widely applied scenarios for stablecoins.