New Era of Stablecoin Regulation: Reshaping the Global Financial Order

Abstract

The market value of stablecoins has reached 260.7 billion USD, accounting for about 1% of the US GDP, with over 170 million users. Governments around the world are strengthening regulations, driven by core motivations including financial stability, monetary sovereignty, and cross-border capital control. The US, Hong Kong, and others have launched systemic regulations, marking the entry of global stablecoins into a strong regulatory era, and the international financial landscape is being restructured. Stablecoins have become a strategic focus in financial sovereignty, infrastructure, and pricing power. Despite improving financial efficiency, stablecoins still face challenges such as anchoring risks, decentralization contradictions, and cross-border regulation.

Introduction

In July 2025, the United States passed the GENIUS Act to regulate stablecoins, and the CLARITY Act was submitted to the Senate for review. Countries are introducing policies one after another: Hong Kong implemented the Stablecoin Ordinance in August, Russia provided crypto custody, and Thailand launched a crypto sandbox. The era of stablecoin regulation has officially begun, and the competition among major powers has started.

This article analyzes the reasons for stablecoin legislation in various countries, compares the similarities and differences of the bills, and discusses the impact on financial order, providing references for the industry. It is recommended to pay attention to regulatory trends, participate in fiat-backed stablecoins, and avoid the risks of algorithmic stablecoins. Traditional financial institutions should explore asset tokenization, while crypto institutions should promote compliance processes.

1. Overview of Stablecoins

1.1 Definition and Classification

Stablecoins are cryptocurrencies designed to maintain price stability, typically pegged to fiat currencies, commodities, or other assets, or using algorithmic adjustment mechanisms. Based on the method of price maintenance, they can be classified as:

• Fiat-backed: such as USDT, USDC, accounting for 92.4% market share
• Crypto asset collateralized: such as DAI, using an over-collateralization mechanism
• Algorithmic stablecoin: such as USTC, relies on supply and demand to adjust the price

1.2 Features

• Price stability
• Connect traditional finance with DeFi
• Low-cost high-efficiency payment
• Anti-inflation and capital hedging

1.3 Main Application Scenarios

Decentralized finance, cryptocurrency trading, cross-border trade, daily payments, capital hedging, etc. Cross-border trade is a key area of focus for legislation in various countries.

2. Legislative Background

2.1 The Rise of Stablecoins

The global stablecoin market value is $260.7 billion, surpassing the market value of MasterCard, accounting for about 1% of the U.S. GDP. There are over 170 million users distributed across more than 80 countries.

2.2 Reasons for Government Intervention

• Prevent systemic financial risks
• Maintain currency sovereignty and financial order
• Crack down on illegal cross-border capital flows
• Hedge against the impact of "U.S. Dollar Stablecoin Dominance"
• Mitigating fiat credit risk, supporting government bonds

3. Regulatory Developments in Major Global Economies

3.1 U.S. "Genius Act" and "Clarity Act"

Core content of the "Genius Act":

• Federal and state dual-track regulation
• Limited Issuance Subject
• 1:1 fiat reserve requirement
• Transparency Obligations
• Business Restrictions
• Cross-border restrictions

The Clarity Act clearly defines the regulatory division between the SEC and CFTC.

3.2 Hong Kong "stablecoin regulations"

Main content:

• Licensing system
• Focus on fiat-backed stablecoins
• Minimum capital of 25 million HKD
• 100% reserve requirement
• Strict Anti-Money Laundering and Consumer Protection
• Violations may incur criminal liability.

3.3 Other Economic Dynamics

The EU, Singapore, Japan, and others are actively promoting relevant regulatory frameworks. Overall, there is a cautious and tightening trend, with pledge-based stablecoins as the main regulatory focus.

4. Reshaping Financial Order Under the Dominance of Stablecoins

4.1 Financial Sovereignty Competition

The US dollar stablecoin dominates, continuing the US dollar hegemony. The "Genius Act" strengthens the binding of stablecoins to US Treasury bonds, solidifying the dollar's position. Other countries promote local currency stablecoins to hedge against the impact.

4.2 Financial Infrastructure Competition

Stablecoins have become the core of the new generation of cross-border payment and settlement infrastructure. The United States is attempting to replicate the SWIFT hegemony, while Hong Kong and others are competing for the status of cross-border financial hubs.

4.3 Competition for Pricing Power of Digital Assets

USDT/USDC monopolizes the cryptocurrency market trading pairs, while the United States strengthens its pricing power through legislation. Other regions are promoting regional fiat stablecoins to gain more pricing power.

5. Risks and Challenges

Systemic Risk

Price decoupling risks, such as historical decoupling events of BitUSD and USDC. It is necessary to做好资产多元化配置.

5.2 violates the principle of decentralization

Mainstream stablecoins rely on centralized entities, which goes against the original intention of blockchain. They face credit risks and regulatory pressure.

5.3 Difficulties in Coordinating Cross-Border Regulation

The regulatory frameworks of different countries vary greatly, making it easy to create regulatory arbitrage and compliance gaps.

5.4 Potential Financial Sanction Risks

US dollar stablecoins may become a tool for financial weaponization, increasing political and compliance risks.

Conclusion

Stablecoins have become a key element in the restructuring of monetary order in the digital financial era. Their development is not only related to the integration of DeFi and real assets but also affects the construction of a new global financial order. In the future, there will still be many challenges, and how to balance regulation and innovation will be a core issue for the industry.