Author: imToken; Source: Bulu Shuo

Published in the financial media Forbes on December 23, 2024 An article on the website states: Stablecoin has become one of the most successful asset use cases in the crypto space, relying on blockchains such as Ethereum, Solana and Tron to significantly facilitate cross-chain transactions.

In 2024, the circulating supply of Stablecoin in the Web3 world will reach a record high of 200 billion. It is expected that the circulating supply may continue to grow in 2025, exceeding 400 billion indivual.

In addition, since 2024, institutions actively participating in the Stablecoin market competition include Circle, Tether and other Stablecoin professional issuers, as well as Revolut, which provides banking technology services, and Well-known financial technology companies such as Ripple of payment solutions, as well as traditional banking institutions and financial regulatory agencies are also actively participating in the layout of Stablecoin.

Among them, the performance of Ripple's recently issued Stablecoin RLUSD has attracted the most attention. On December 11, 2024, Ripple CEO Brad Garlinghouse said on his X platform social account: Ripple’s plan to issue RLUSD has been approved by the New York State Department of Financial Services. As of 20:51 on January 2, 2025, according to real-time data displayed by CoinMarketCap, the total supply of RLUSD has reached 53.09 million, and the transaction volume within 24 hours was US$25.65 million.

On December 30, 2024, the EU Markets in Crypto-Assets Regulation (The EU Markets in Crypto-Assets Regulation, below The MiCA Act has been officially implemented, but it has once again caused a wave of waves in the Stablecoin market, especially concerns that the use of Tether's USDT in the EU will cause non-compliance. Earlier, Coinbase. Other trading platforms have chosen to respond to the MiCA bill with caution.Implementation, in October 2024, the decision to delist USDT for EU users was revealed.

2025 has already begun, and the official implementation of the EU MiCA Act has opened a new chapter for the global regulatory practice of digital assets, including Stablecoin. When we review the regulatory measures for Stablecoin in mature digital asset markets such as the European Union and the United States, can we see any common patterns? What is the regulatory situation in emerging blockchain markets such as Singapore, Hong Kong, and the Middle East? What challenges will they face?

European Union

Some media articles pointed out that the full and formal implementation of the MiCA Act can be seen as a statement of the EU’s attitude towards crypto assets: We welcome crypto assets, but they must be done responsibly And use it in a safe way.

About the MiCA Act

Legislative purpose: to ensure that EU legislation on financial services adapts to the needs of today's digital age and future economic development, and to promote the active adoption of distributed ledgers in the financial sector Transformative technologies, including technology, promote new business activities and models. These new business formats and crypto-assets will together bring economic growth and new job opportunities to the EU.

△ Implementation time chart of MiCA Act Source: ESMA

About Stablecoin< p style="text-align: left;">Definition: Stablecoin is a crypto-asset defined in the EU MiCA Act, and the MiCA Act defines two forms for the crypto-asset industry: Electronic Money Tokens (EMTs) and Asset-Referenced Tokens (ARTs for short), which is equivalent to excluding forms such as algorithmic Stablecoin.

Licensing: According to the European Times, Marina Markezic, co-founder of the European Encryption Initiative (EUCI), once said that the MiCA Act provides a unified regulatory framework that will Through the "license pass" system, companies can operate within the entire trade area after obtaining regulatory permission from a member country.

This means that according to the requirements of the MiCA Act, STablecoin issuers need to obtain authorization to operate. USDT, which is already facing concerns about a ban on issuance, urgently needs Tether, as the issuer, to decide whether to use the transition period to carry out compliance reforms.

For details of the MiCA Act, please visit: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri= CELEX%3A32023R1114&qid=1735820498947

United States

There is no specific target for Stablecoin in the United States The complete regulatory framework, but some of the regulatory bills on digital assets that have not yet taken effect and are in the legislative process involve the supervision of Stablecoin. Bills worthy of attention include:

▶The 21st Century Financial Innovation and Technology Act (commonly referred to as the FIT21 Act): involves the jurisdiction of digital assets including Stablecoin.

For details of the FIT21 bill, please check:

https://www.congress.gov/bill/118th-congress/house-bill/4763/text?s=1&r=1&q=%7B"search"%3A%5B"Financial+Innovation +and+Technology+for+the+21st+Century+Act."%5D%7D

For more information, please check: Will the approval of Ethereum spot ETF be beneficial? Let’s learn about the FIT21 bill that is hotly discussed in the industry

▶"The Lummis-Gillibrand Payment Stablecoin Act" (the Lummis-Gillibrand Payment Stablecoin Act) ): Relates to providing prudential supervision and consumer protection for issuers of payment Stablecoin; authorizing state non-depository trust companies to issue payment Stablecoin; authorizing state depository institutions to issue payment Stablecoincoin; requires the issuing institution to set up a reserve equal to the payment of Stablecoin to prevent risks and other matters.

The above bill was introduced by U.S. Senators Cynthia Lummis and Kirsten Gillibrand on April 17, 2024.

"Loomis-Gillibrand Pays Stablecoin Act"

theLummis-Gillibrand Payment Stablecoin Act

For details, please visit:https://www.congress.gov/bill/118th-congress/senate-bill/4155/text

▶"The Clarity for Payment Stablecoins Act of 2023": To pay for Stablecoins Established issuance standards, reporting requirements, established consumer protection regulations, and clarified that payment of Stablecoin is not a security or commodity.

The above bill was submitted to the House of Representatives in July 2023. On May 7, 2024, a new sponsor was added and an amended bill was submitted.

The Clarity for Payment Stablecoins Act of 2023

The Clarity for Payment Stablecoins Act of 2023

For details, please visit: https://www.congress.gov/bill/118th-congress/house-bill/4766/text

▶ In addition to the above-mentioned bills, as early as June 2015, the State of New York has passed the New York Financial Services Act (New York Financial Services Law) issued regulations for virtual Currency (Part 200 Virtual Currency Regulation), including the well-known BitLicense licensing requirements, and digital asset service providers including Stablecoin issuers need to obtain a license Only then can relevant business be carried out in New York State. In June 2022, the New York State Department of Finance announced regulatory guidance for US dollar-anchored Stablecoin.

New York State Virtual Currency Regulations

For details, please visit:https://govt.westlaw.com/nycrr/Browse/Home/NewYork/UnofficialNewYorkCodesRulesandRegulations?guid=I7444 ce80169611e594630000845b8d3e&originationContext=documenttoc&transitionType=Default&contextData=(sc.Default

Singapore

According to a report on December 28, 2024, Chia Der Jiun, Managing Director of the Monetary Authority of Singapore, said in an interview with the Business Times: Stablecoin has the potential to become a A widely used payment instrument will have a high degree of stability if it is well regulated.

On August 15, 2023, the Monetary Authority of Singapore announced its official announcement. Release Stablecoin Regulatory framework, applicable to single currency Stablecoin pegged to the Singapore dollar or any G10 currency (including the US dollar, euro, Japanese yen, Swiss franc, Canadian dollar, Australian dollar, British pound, Norwegian krone, New Zealand dollar, etc., but excluding the renminbi), aiming to In promoting the use of Stablecoin as a medium and bridge for trusted digital exchange, currency and digital ecosystem

Singapore’s Stablecoin regulatory framework. Prevent risks Stablecoin issuers have set higher requirements, such as tying currency reserves to issuanceThe number of Stablecoin issued in the industry is required to be equal to or greater than 1:1. At the same time, Stablecoin issuers are also required to be prohibited from engaging in business, meet minimum asset adequacy, and ensure minimum liquidity assets in operations.

Financial Regulatory Authority of Singapore’s response to the public consultation on the proposed regulatory approach to Stablecoin-related activities

Details Please check:

https://www.mas.gov.sg/-/media/mas-media-library/publications/consultations/pd/2023/response-to-consultation-on-stablecoins-regulation_15aug2023.pdf

Abu Dhabi

December 5, 2024 On the same day, the Financial Services Authority of Abu Dhabi Global Market issued the Financial Services and Markets (Amendent No.1) Regulations 2024) (Financial Services and Markets (Amendent No.1) Regulations 2024), which defines The specific form of Stablecoin-type digital assets in the UAE market makes it clear that the issuance of relevant digital assets is not a payment activity, and it is determined that Stablecoin transactions are a type of payment activity.

Shortly after the release of the above-mentioned amended regulations, according to media reports on December 10, 2024, Tether has received authorization approval from the Abu Dhabi Financial Services Authority, USDT will be issued compliantly in the UAE.

Abu Dhabi Financial Services Authority issued the "Financial Services and Markets (Amendment No. 1) Supervision Regulations"

For details, please see:https://adgmen.thomsonreuters.com/sites/default/files/net_file_store/Financial_Services_and_Markets_(Amendment_No.%201)_Regulations_2024.pdf

Hong Kong

On December 6, 2024, Hong Kong announced the full text of the Stablecoin Bill. The bill defines Stablecoin and Stablecoin-related activities, sets detailed licensing requirements, and explains Regulatory regulations require service providers to obtain authorization before they can operate in the Hong Kong market.

The Hong Kong Monetary Authority released a discussion paper on Stablecoin-related bills as early as January 2022, and has been working on discussion papers on related bills in 2023. Consult and gather opinions.

In March 2024, the Hong Kong Monetary Authority also launched the Stablecoin Issuer Sandbox Program and announced the sandbox participant list on July 18, 2024. They are JD Coin Chain Technology (Hong Kong) Co., Ltd., Yuanbi Innovation Technology Co., Ltd., Standard Chartered Bank (Hong Kong) Co., Ltd. and Anhui Group Co., Ltd.

Hong Kong StablecoinBill

For details, please check: https://www.gld .gov.hk/egazette/english/gazette/file.php?year=2024&vol=28&no=49&extra=0&type=3&number=31

Although different regions and regions have adopted different legal frameworks for the supervision of Stablecoin, some common regulatory principles still emerge, as shown in:

Stablecoin is defined, and algorithm Stablecoin is basically excluded.

Implementing a licensing access system, that is, the issuer of Stablecoin must obtain explicit authorization and approval from the regulatory agency before entering the relevant market operation.

Clearly required to set up reserves to prevent risks. The minimum reserve requirement is 1:1 anchored to the issued Stablecoin.

However, the regulatory differences are also very obvious. The European Union has included Stablecoin in the category of encrypted assets (or digital assets) for supervision; although the United States does not yet have a special and complete regulatory framework for Stablecoin at the federal level, it currently involves Stablecoin and is in the legislative process. There are still obvious inconsistencies in the definition and jurisdiction of Stablecoin under different laws; while Singapore, Abu Dhabi, and Hong Kong have relatively clear jurisdiction over Stablecoin.

Compared with the comprehensiveness of the EU MiCA Act, the regulatory frameworks of the United States, Singapore, Abu Dhabi, and Hong Kong have different emphasis on Stablecoin, which also reflects the Stablecoin market in each region. There are differences in development goals and market status. For example, the United States, Singapore, and Abu Dhabi focus on the supervision of payment applications, while Hong Kong focuses on access licensing.

There are still many hollow areas in the regulation of Stablecoin. For example, there is a lack of legislative connection when using Stablecoin to pay across different jurisdictions, and transactions between Stablecoins anchored to different single legal currencies. The regulatory specifications, as well as how to set up supervision for Stablecoin anchored to multiple currencies or other values, the exchange supervision of Stabelcoin, etc.