With the passage of stablecoin-related bills in the United States and Hong Kong, the global digital asset market has officially entered a new growth cycle driven by regulation. The implementation of this regulation not only fills and improves the regulatory gap of stablecoins anchored to fiat currency assets, but also provides the market with a clear compliance framework, including reserve asset isolation, redemption guarantees and anti-money laundering compliance requirements, effectively reducing systemic risks (such as bank runs or fraud).

This article analyzes the core framework of the two bills and combines quantitative forecasts to systematically look forward to the ten-year growth trajectory of compliant US dollar stablecoins and their effects on the reconstruction of the public chain ecosystem.

1. Growth momentum and quantitative deduction of US dollar stablecoin under the GENIUS Act

The US GENIUS Act (Guiding and Establishing National Innovation for US Stablecoins Act) was passed by the Senate in May 2025, marking a key step in the regulation of stablecoins in the United States. The bill sets out a detailed regulatory framework for stablecoin issuers, requiring them to hold reserves backed by highly liquid assets such as US dollar cash, short-term US Treasury bonds or government money market funds at a ratio of at least 1:1 , and to undergo regular audits and comply with compliance requirements such as anti-money laundering ( AML ) and know your customer ( KYC ). In addition, the bill prohibits stablecoins from providing interest income, restricts foreign issuers from entering the US market, and clarifies that stablecoins are neither securities nor commodities, thus providing a clear legal position for digital assets. This legislation aims to strengthen consumer protection and guard against financial risks, while providing a stable regulatory environment for financial technology innovation.

The implementation of the GENIUS Act is expected to have a profound impact on the global crypto market landscape. First, investing in highly liquid dollar assets that are not allowed to generate interest will directly benefit the issuance of U.S. debt, making stablecoins an important channel for the distribution of U.S. debt. This mechanism not only eases the financing pressure of the U.S. fiscal deficit, but also strengthens the international settlement status of the U.S. dollar through digital currency channels. Secondly, a clear regulatory framework may attract more financial institutions and technology companies to enter the stablecoin field, promoting innovation and efficiency of the payment system. However, the bill has also sparked some controversy, such as the potential conflicts of interest brought about by the involvement of former President Trump's family in the cryptocurrency industry, and the international regulatory coordination issues that may arise from restrictions on foreign issuers. Nevertheless, the GENIUS Act provides institutional guarantees for the development of stablecoins, marking an important step for the United States in the global competition for digital asset regulation.

According to Citigroup's forecast, under the scenario of clear regulatory path, the global stablecoin market value will grow from US$ 230 billion in 2025 to US$ 1.6 trillion in 2030. It is worth noting that this forecast implies two key assumptions: first, compliant stablecoins will accelerate the replacement of traditional cross-border payment channels, saving about US$40 billion in international remittance costs each year; second, the amount of stablecoins locked in DeFi protocols will exceed US$500 billion, becoming the basic liquidity layer of decentralized finance.

2. Differentiated positioning of Hong Kong’s stablecoin regulatory framework

The Stablecoin Ordinance recently issued by the Hong Kong SAR government marks an important progress in its systematic layout in the field of Web3.0. The Ordinance establishes a licensing system for the issuance of stablecoins, requiring issuers to obtain a license from the Hong Kong Monetary Authority (HKMA) and meet strict requirements in terms of reserve asset management, redemption mechanism and risk control. In addition, Hong Kong also plans to launch a dual licensing system for over-the-counter (OTC) and custody services in the next two years to further improve the full-chain regulatory system for virtual assets. These measures are aimed at strengthening investor protection, improving market transparency and consolidating Hong Kong's position as a global digital asset center.

The Hong Kong Monetary Authority plans to release operational guidelines on the tokenization of real-world assets (RWA) in 2025 to promote the on-chain tokenization of traditional assets including bonds, real estate and commodities. Through smart contract technology, automatic dividends and interest distribution functions are realized. Hong Kong is committed to building an innovative ecosystem that integrates traditional finance and blockchain technology, opening up a broader application space for the development of Web3.0. Under Hong Kong's regulatory framework, the issuance of stablecoins will present a prosperous development trend of multiple currencies and multiple scenarios, further consolidating Hong Kong's position as a technology and financial hub.

Although the Hong Kong Stablecoin Bill draws on the regulatory logic of the United States, it shows significant differences in implementation details (see Table 1 ):

Table 1: Comparison of stablecoin regulatory frameworks in the United States and Hong Kong

3. The evolution of the global stablecoin landscape under regulatory competition

1. The strengthening effect of the US dollar stablecoin as a global reserve currency

Under the regulatory framework established by the GENIUS Act, payment stablecoins must use U.S. Treasury bonds as reserve assets. This provision gives the U.S. dollar stablecoins strategic significance beyond the scope of digital currencies . In essence, this type of stablecoin has become a new distribution channel for U.S. Treasury bonds, building a unique capital circulation system on a global scale: when global users purchase stablecoins denominated in U.S. dollars, the issuing institution must allocate the corresponding funds to U.S. Treasury assets, which not only realizes the return of funds to the U.S. Treasury, but also invisibly strengthens the global use of the U.S. dollar. This mechanism can be seen as a global extension of the U.S. dollar financial infrastructure.

From the perspective of international settlement, the emergence of stablecoins marks a paradigm shift in the US dollar clearing system. In the traditional model, cross-border flows of US dollars are highly dependent on interbank settlement networks such as SWIFT, while blockchain-based stablecoins are directly embedded in various compatible distributed payment systems in the form of "on-chain dollars". This technological breakthrough means that the US dollar settlement capabilities are no longer limited to traditional financial institutions. This not only expands the international use scenarios of the US dollar, but also represents the modernization and upgrading of the US dollar settlement sovereignty in the digital age, further consolidating its core position in the global monetary system.

2. Challenges of Asian Regulatory Coordination between Hong Kong and Singapore

Although Hong Kong took the lead in establishing a stablecoin license system, the "stablecoin sandbox" launched by the Monetary Authority of Singapore (MAS) at the same time allows the experimental issuance of tokens pegged to existing fiat currencies. Regulatory arbitrage between the two places may trigger "regulatory site selection" behavior by issuers, and a unified reserve audit standard and anti-money laundering information sharing mechanism need to be established through the ASEAN Financial Regulatory Forum.

Although Hong Kong and Singapore have similar goals in their stablecoin regulatory policies, their implementation paths are significantly different. Hong Kong adopts a prudent and tightening regulatory approach. The HKMA plans to establish a legal stablecoin license system, positioning stablecoins as "virtual bank substitutes" and strictly following the traditional financial regulatory framework. In contrast, Singapore adheres to the concept of experimental supervision, allowing innovative pilot projects that link digital tokens to legal currencies, reserving flexible space for technological and business model innovation, and adopting an overall trial-and-error regulatory attitude.

Such regulatory differences may lead to selective registration by issuers to circumvent strict scrutiny, or to conduct arbitrage operations by taking advantage of differences in regulatory standards, thereby weakening the audit effectiveness of the fiat currency peg mechanism. In the long run, if there is a lack of coordination, such differentiation may undermine regulatory fairness and policy consistency, and even trigger the risk of regional regulatory competition, causing the two places to fall into a friction-based competition. In addition, the lack of uniformity in regulatory standards may weaken Asia's voice in the global stablecoin system, thereby affecting the competitiveness of Hong Kong and Singapore as international financial centers.

Regulators in both places need to strengthen policy coordination and seek a better balance between preventing systemic risks and encouraging financial innovation to enhance Asia's overall influence in global digital financial governance.

Conclusion: Regulatory Clarity Opens the Golden Decade of Stablecoins

The joint implementation of the US GENIUS Act and the Hong Kong Draft Ordinance marks the transition of digital asset regulation from fragmentation to systematization. Compliant US dollar stablecoins will achieve an order of magnitude growth within ten years and become the core bridge connecting traditional finance and the crypto ecosystem. The technological evolution of the public chain infrastructure determines whether it can capture the maximum value dividend within the regulatory framework. For issuers, building a multi-chain, multi-currency, and multi-regulatory compatible stablecoin system will be a key strategy to win the competition in the next decade.

(Note: The data model in this article is based on Citigroup's April 2025 report, the hearing records of the U.S. Senate Banking Committee, and the public documents of the Hong Kong Monetary Authority. The growth forecast has taken into account macroeconomic volatility and technical risk factors.)