Overview of Stablecoin Regulatory Trends in Major Regions Worldwide

In recent years, the rapid development of stablecoins in the cryptocurrency field has attracted significant attention from global regulatory agencies. As a type of digital currency that is pegged to fiat currencies or other assets, stablecoins are widely used in areas such as cross-border payments and decentralized finance due to their stable value characteristics. Especially in the current market cycle, the tokenization of physical assets has been prominent, attracting active participation from traditional financial institutions and Web3 native organizations, and the interest of investors in this field is also growing.

With the expansion of the stablecoin market, governments and international organizations around the world have introduced relevant policies to regulate and supervise the issuance and use of stablecoins. This article will briefly overview the current regulatory dynamics of stablecoins in major regions globally.

United States

As one of the main markets for the development of stablecoins, the regulatory policies in the United States are quite complex and are implemented by multiple agencies. The main regulatory bodies include the Department of the Treasury, the Securities and Exchange Commission (SEC), and the Commodity Futures Trading Commission (CFTC).

The SEC may consider certain stablecoins as securities and require them to comply with the relevant provisions of the Securities Act. The Office of the Comptroller of the Currency (OCC), under the Department of the Treasury, had 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. Currently, the U.S. Congress is discussing legislative proposals such as the Stablecoin Transparency Act, aimed at establishing a unified regulatory framework for stablecoins.

European Union

The EU's stablecoin regulation is primarily based on the Markets in Crypto-Assets Regulation (MiCA). MiCA categorizes stablecoins into two types: Asset-Referenced Tokens (ART) and Electronic Money Tokens (EMT).

Electronic money tokens refer to tokens that are pegged to a single fiat currency, such as stablecoins pegged to the euro or the US dollar. Asset reference tokens refer to tokens that are pegged to certain assets (such as fiat currencies, commodities, or crypto assets). MiCA has established corresponding regulatory requirements for these two types of tokens, including obtaining authorization from EU member states, meeting capital reserve requirements, and transparency disclosures.

Hong Kong

The Hong Kong Monetary Authority and the Financial Services and the Treasury Bureau published a summary of the consultation on the stablecoin regulatory framework in July 2023. According to this framework, companies issuing or promoting fiat stablecoins to the public in Hong Kong are required to obtain a license from the Monetary Authority. The regulatory requirements cover aspects such as reserve asset management, corporate governance, risk control, information disclosure, and anti-money laundering.

The Monetary Authority also launched a "sandbox" program for stablecoin issuers to facilitate communication with the industry regarding regulatory requirements. In December 2023, the Hong Kong government published the "Stablecoin Bill" in the Gazette, aiming to improve the regulatory framework for virtual asset activities.

Singapore

Singapore regards stablecoins as digital payment tokens, and their issuance and circulation require approval from the Monetary Authority of Singapore (MAS). MAS provides a regulatory sandbox for startups to test business models related to stablecoins.

Japan

In June 2022, Japan revised the Payment Services Act (PSA) to establish a regulatory framework for the issuance and trading of stablecoins. The revised PSA defines stablecoins fully backed by fiat currency as "electronic payment instruments" (EPI). Only three types of institutions—banks, money transfer service providers, and trust companies—are allowed to issue stablecoins. Institutions wishing to engage in stablecoin-related activities must first register as electronic payment instrument service providers (EPISP).

Brazil

Roberto Campos Neto, the president of the Central Bank of Brazil, stated that there are plans to regulate stablecoins and asset tokenization in 2024. In November 2023, the central bank proposed a regulatory proposal suggesting to restrict users from withdrawing stablecoins from centralized exchanges to self-custody wallets. However, it has been reported that the central bank may consider lifting this restriction if key issues such as transaction transparency can be improved.

Summary

Countries around the world are actively exploring best practices for stablecoin regulation. Whether through the establishment of regulatory sandboxes or by formulating policies based on the different characteristics of stablecoins, more regulatory measures for stablecoins are expected to be introduced in the future. The cross-border payment sector is likely to become one of the most widely applied scenarios for stablecoins. With the gradual improvement of the regulatory framework, the stablecoin market is expected to achieve healthier and more orderly development.