Author | Wu Says Blockchain

In this podcast, we've invited the well-known and popular analyst Zheng Di. He has worked at several major securities firms and has long been active in mainland China, Hong Kong, and Singapore, with in-depth research on the Web3 industry.

In recent years, Hong Kong has demonstrated strong momentum in terms of policy inclusiveness and industry layout, attracting a growing number of crypto practitioners. In particular, amid tightening regulations in Singapore, some centralized exchanges and Chinese-based practitioners that have been unable to obtain licenses or face other restrictions have begun to turn their attention to Hong Kong.

At the same time, many are skeptical of Hong Kong's development, believing it lacks the conditions to become a Web3 hub. Especially against the backdrop of mainland China's frequent policy fluctuations, Hong Kong's stablecoins and RWAs (tokenized real-world assets) have become a hot topic and garnered widespread attention.

Zheng Di currently resides in Singapore but travels between Hong Kong and Singapore frequently, making him deeply familiar with the policy environments and market dynamics in both places. In this episode, he will detail the similarities and differences between Hong Kong and Singapore's Web3 regulatory approaches, exploring whether Hong Kong can stand out as a global hub for the next generation of the crypto industry. He will also delve into stablecoin market trends, the regulatory landscape for stock tokenization, and the significant differences between China and the US in the development of RWAs.

For the full audio, search for "Wu Shuo" on mainstream audio platforms at home and abroad, such as Xiaoyuzhou. This article does not constitute investment advice, and the author's views do not necessarily reflect those of Wu Shuo. Readers are advised to strictly abide by local laws and regulations.

Comparing Regulatory Approaches in Hong Kong and Singapore: The Battle for the Web3 Center

Colin: First, I'd like to ask Professor Zheng Di to share his thoughts on why he believes Hong Kong will become the next Web3 center. Will it be an Asia-Pacific center or a global center?

Zheng Di: Okay, thank you, Colin. Hello everyone, it's a great honor to discuss this topic with you again today.

In fact, I believe Singapore is under regulatory pressure, particularly from the FATF (Financial Action Task Force), which requires its member countries to regulate all virtual asset service providers (VASPs) registered in their country, even if those services are not located within their territory. Therefore, Singapore's recent regulatory actions, including the introduction of the DTSP license, are in response to this international regulatory pressure.

Singapore actually announced this policy as early as 2022. However, many practitioners in Singapore were unaware of it at the time, perhaps believing there might be a grace period or that obtaining a license was easy. Therefore, the complete implementation of this "regulatory cliff" on June 30, 2025 was quite surprising—no transition period, a direct cutoff, resulting in a large number of practitioners being forced to leave.

The departure of some small exchanges is not surprising, but what shocked me was that even well-known listed platforms in Singapore, already licensed in Hong Kong, were forced to withdraw due to the inability to obtain a Singaporean license. This shows that Singapore is indeed reluctant to continue to accommodate these institutions.

This doesn't mean Hong Kong isn't under regulatory pressure. As a member of the FATF, Hong Kong will also be assessed. It's simply because Singapore's assessment preceded it, and the pressure was felt earlier. If Singapore fails to clean up the relevant platforms in this assessment, it could be placed on a "gray list" or even a "blacklist," significantly impacting its status as an international financial center and capital flows.

Hong Kong, on the other hand, faces a shortage of options. In the past few years, a large number of international institutions, including Chinese companies, have chosen Singapore, not just Web3 finance. Even if Singapore loses Web3, it still has other sectors like AI to support it, so it lacks a strong incentive to embrace Web3.

But Hong Kong is different. A few years ago, it was even called the "international financial ruins," and it urgently needed to find a new direction for development. Web3 has become a breakthrough point chosen by policymakers. Singapore's sovereign wealth fund has previously suffered significant losses in the Web3 and NFT sectors, which has also soured the government's perception of the industry.

Singapore has publicly stated that it will not issue too many DTSP licenses. This is driven by considerations of the industry's contribution: the Web3 industry does not provide sufficient local employment and tax revenue, and many people receive their salaries in stablecoins, publicly paying very little tax. Citizens have also complained that Web3 workers are driving up the cost of living. Furthermore, with 2025 being an election year, increased government regulation is also a response to public opinion.

Thus, Singapore has simply restricted the number of licenses, "driving away" certain industries. Hong Kong, facing the same regulatory pressure due to a lack of alternative industries, has adopted a relatively flexible approach, such as providing a transition period and clear licensing guidelines.

In short, while both cities face the same external regulatory pressure, their approaches to Web3 differ significantly due to their different industrial structures and options. This reflects the differences in their strategic positioning of the Web3 industry.

Hong Kong's Evolving Position: The Potential for a Global Web3 Hub, From a Greater China Center

Colin: I think Professor Zheng Di has explained Singapore's background very clearly, and why Singapore is currently showing a trend of "driving people away." So, can we continue our discussion on Hong Kong? Do you think Hong Kong is more of a Greater China Web3 center, or could it become an Asia-Pacific center, or even a global center?

Zheng Di: In fact, if it weren't for the recent changes since April of this year, I would have thought Hong Kong was just a Greater China Web3 center, relying primarily on mainland China for support. Hong Kong's Web3 development is largely driven by the local government's industrial policies. Therefore, many people in the market have been cynical about projects and practitioners that relocated to Hong Kong or Cyberport.

But we can't ignore the question: Will China's policy stance remain static forever? In the Web3 industry, I personally feel that Chinese people, especially those of Asian descent, experience a sense of shame—because the industry is not encouraged in China, with only marginalized spaces like Hong Kong to thrive, and lacking clear, positive regulatory guidance. Meanwhile, the United States has actively led the development of rules for this industry. Since Trump's election, the US has continuously introduced crypto-friendly regulatory frameworks. For example, the GENIUS Act, recently passed by the House of Representatives, although the Senate version has not yet been released and lacks mandatory long-arm jurisdiction, does clearly state that foreign stablecoin issuers who fail to comply with its regulations will be excluded from the US-dominated crypto-financial system. Therefore, many jurisdictions, including Hong Kong, may be seeking to align with the US regulatory framework to achieve "mutual recognition," thereby allowing compliant stablecoin issuers to smoothly enter the US market. This reliance on US standards makes it difficult for Hong Kong to escape its "away-from-home" status, even as it strives to develop Web3. However, we have recently observed a shift in policy direction. In particular, the CNH stablecoin, launched in partnership with the Hony Capital Group, making the front page of the Liberation Daily is a truly special signal. Furthermore, the Shanghai State-owned Assets Supervision and Administration Commission and the Wuxi government are also studying stablecoins, and public statements at the Lujiazui Forum on June 18th also sent a positive message.

These developments suggest that mainland China's policies are undergoing subtle adjustments. Therefore, Hong Kong's role is no longer limited to being a hub for Greater China; it has the potential to become a Web3 hub for all of Asia. Even if we ignore the mainland market, Hong Kong already has a solid foundation based solely on the overseas applications of Chinese companies and banks.

From a global perspective, despite fierce competition with the United States in areas such as trade, tariffs, and technology, China has never been able to establish pricing power over financial assets. This is because Western financial rules remain dominated by the United States, and most countries around the world follow its regulatory framework.

Today, we are at an unprecedented juncture in the restructuring of our financial system. The once seamless SWIFT system is undergoing an upgrade, and the United States hopes to lead this upgrade and quickly address any "gaps" that may arise during the process, thereby further consolidating its dominance in the on-chain financial system.

The latest provisions of the Genius Act clearly reflect this intention, but this also presents a rare and historic opportunity for China. If China can seize this window of opportunity, while on-chain financial infrastructure remains relatively open, and secure a voice, it will not only be able to participate in the construction of the new system but also potentially challenge existing financial hegemony.

On-chain finance is not something that any single country or government can build alone; it is the result of over a decade of collaborative effort by users, project developers, and investors worldwide. The United States excels at setting rules to achieve indirect control, but if China can participate in the rule-making process, it could potentially counter them.

If China introduces more friendly policies at this stage and encourages local companies to participate in on-chain finance, particularly in key areas such as stablecoins, RWAs (real-world assets on-chain), and STOs (security tokens), then Hong Kong has the potential to become not only an Asian hub but also a new global Web3 hub, alongside cities like New York.

From an offshore financial perspective, the Global South—the 30 to 50 countries with foreign exchange controls or significant currency fluctuations—presents the most practical application scenarios for on-chain finance. If China can capitalize on this market, it will have a significant advantage in on-chain stablecoin and asset trading.

Therefore, I believe now is a window for China to make policy decisions. If it seizes this opportunity, China and the United States could jointly shape the on-chain financial landscape over the next three to five years. Otherwise, this window could quickly close.

In summary, I believe Hong Kong has at least become a Web3 hub in Asia and is on its way to becoming a global hub. Whether this goal can ultimately be achieved depends on whether the Chinese government can make the right strategic choices at critical moments.

Hong Kong's Battle for Stablecoin Licenses: The Game Between USDT Hegemony and the Regulatory Window

Colin: There are also some concerning issues in Hong Kong, such as the "Global South" you just mentioned. USDT is now widely used in developing countries. If Hong Kong wants to relaunch a stablecoin, especially one denominated in RMB or HKD, it would be directly competing with USDT. Wouldn't that be too challenging? Furthermore, mainland China, and especially Beijing, has an unclear stance on this matter. Past policy fluctuations make it difficult to judge whether this issue can truly rise to the national level.

Zheng Di: Actually, before I saw the US House of Representatives pass the Genius Act, I agreed with your view. Indeed, USDT is like a "giant," practically unbeatable in offshore scenarios. However, after the House version of the Genius Act passed, and especially after Trump signed it, USDT was forced to enter regulatory compliance. There is a three-year transition period. According to Tether's CEO, Tether will issue a fully compliant stablecoin registered in the US, primarily serving institutional, high-speed, and transparent payment scenarios. USDT will remain a "foreign issuer," and hopefully will continue to have smooth access to the US and even the broader Western crypto-financial system.

However, during this process, USDT will also have to make adjustments, such as changing its reserve structure to meet the requirements of the Genius Act. This means its excess returns will cease to exist. While USDT will continue to earn a lot of money during this three-year period, after that, it must fully comply with regulations, establishing a blacklisting mechanism, a Know Your Customer (KYC) system, and anti-money laundering measures.

It is this three-year compliance window that creates new market space and opportunities for offshore stablecoins to develop. Competition in the stablecoin market will become even more intense in the future.

If I were Jeremy (Circle co-founder and CEO), I wouldn't actually want Tether to be overly pressured to comply. This is because the two currently operate in different markets: USDT focuses on the Global South, while Circle is more focused on the US and institutional markets. If USDT becomes compliant, it will shift from its original offshore market focus to the US market, becoming a direct competitor to Circle. This change will disrupt the existing market structure.

Once USDT is brought into compliance, it will create a gap in the existing offshore market, providing growth opportunities for other stablecoins, such as DAI and Ethena. These stablecoins, previously ranked third and fourth, may seize this opportunity to grow.

Yesterday, I saw an interesting news story: Coinbase customer service was compromised by hackers, resulting in the theft of $300-400 million in assets. The hackers converted all of the assets into DAI, and these assets cannot be frozen. Everyone is asking if they can be frozen. If it's USDT or USDC, they can be frozen, but DAI cannot. This also shows that decentralized stablecoins still have "gap" in the offshore market.

Of course, since these algorithmic or crypto-collateralized stablecoins (such as Ethena and DAI) are not fiat-collateralized and will not be recognized by the "Genius Act," they may be completely excluded from the future Western crypto-financial system. Even so, the gap left by USDT's compliance process still provides other players with the opportunity to grow. Does this create an opportunity for new local players like the CNH stablecoin? It's hard to say, but what is certain is that this is indeed a potential window for rising stars. However, Hong Kong also faces very real challenges: on the one hand, mainland policies have indeed loosened, and many people want to seize this opportunity to promote the growth of Hong Kong's Web3 industry; but at the same time, there is also a very powerful conservative force, watching closely, ready to pick on Hong Kong at any time. If anything goes wrong, it will be used as a target.

That's why the HKMA is currently exercising great caution. This caution stems from both pressure from the mainland and the requirements of international regulation from the FATF. To maintain its status as an international financial center, it must align with Western regulatory systems, ensuring thorough implementation of know-your-customer (KYC) and anti-money laundering regulations.

Singapore has chosen to comply with strict regulations, even at the cost of "destroying" its local Web3 industry. Although they claim to be "cleaning up non-compliant areas," the results clearly indicate a significant tightening of regulations.

I think Singapore is similar to Shanghai's Zhangjiang Hi-Tech Park in this respect—over-trusting large multinational corporations and neglecting local small and medium-sized innovative forces. Zhangjiang's neglect of innovative pharmaceutical talent returning from overseas led to Suzhou snatching away the opportunity to become China's innovative pharmaceutical center.

Similarly, Hong Kong doesn't have many options. It must preserve the Web3 industry while also coping with regulatory pressure from the FATF.

Hong Kong is clearly cooling down the public interest in stablecoins and is no longer issuing applications easily. The HKMA is currently adopting an invitation-only system—only institutions invited by phone are eligible to apply for stablecoin licenses.

Also, stablecoins in the future may not follow the model of arbitrary transfers on public chains like USDT and USDC. Instead, they may adopt a more cautious whitelist system, perhaps using on-chain deposit transfers based on a whitelist, similar to TMMFs (money market fund tokens).

All of this will depend on how the policy is implemented after August. But my overall feeling now is that the HKMA is more cautious than before. Hong Kong faces a regulatory balancing act under dual pressures: not only internal but also external.

How Hong Kong Responds to Offshore Crypto Services: Finding a Balance Between Regulation and Industry

Colin: Singapore has adopted a rather unusual approach this time. If you are an offshore entity registered in Singapore but serving overseas users instead of local ones, Singapore is currently quite hostile to this approach. Hong Kong, on the other hand, seems to be relatively tolerant in this regard. This is a crucial issue for the cryptocurrency community, as it not only involves offshore centralized exchanges but also decentralized products and even more businesses. Singapore has been more critical in rejecting this model. Do you think Hong Kong might tighten its grip on this in the future? As far as I understand it, Hong Kong is generally relatively tolerant or tolerant.

Zheng Di: Yes, I think the key to this issue lies in the regulatory scrutiny of the FATF. Singapore faced this pressure earlier than Hong Kong, and Hong Kong will undoubtedly face it soon. But judging from its current stance, Hong Kong clearly wants to protect its own Web3 industry, which is a clear difference from Singapore.

Singapore's regulatory strategy relies heavily on large companies, so you'll see they primarily issue licenses to major exchanges and market makers, while smaller projects may be directly dismissed with stigma. Hong Kong, however, is different. It prioritizes small and medium-sized enterprises, recognizing that innovation often stems from these institutions. The US follows a similar approach. Singapore has many options; it doesn't need to rely on these small and medium-sized Web3 startups; it can simply follow the trends. And driven by the current wave of overseas expansion, many Chinese companies are choosing Singapore as their first stop, making Singapore naturally more selective.

But I still believe Web3 is a very important industry. As a senior partner at a US-based fund told me, we only need to focus on two industries in the future: AI and Web3. These two represent the most challenging terrain, and there's no need to devote too much energy to other sectors.

So I also believe the Singapore government may reflect on its current choices in a few years. After all, FATF pressure is global, and Hong Kong won't remain lenient. However, there's still room for maneuver in the government's approach. For example, whether to establish a grace period and avoid a "regulatory cliff" are crucial.

Take the licensing issue for example—do you encourage others to apply? Or do you create numerous obstacles and discourage them altogether? The accessibility and transparency of the entire process determine a region's attitude.

Currently, Hong Kong hasn't significantly clamped down on offshore exchanges and decentralized exchanges, nor has it prohibited them from serving users outside of Hong Kong. I believe there's a possibility of increased regulation in the future. But the key difference in Hong Kong is that it may encourage these institutions to apply for licenses, or even proactively invite them, rather than adopting the "unwelcome" approach or even outright "not issuing" like Singapore.

After issuing licenses to several major exchanges, market makers, and stablecoins, Singapore felt it had enough and no longer considered this industry a core pillar. Hong Kong, however, faces fewer options, and Web3 may be its only strategic industry that can shape its future.

Thus, facing the same pressure from the FATF, the two regions have adopted completely different response strategies.

Of course, that being said, Hong Kong's regulations are also tightening significantly. Previously, we saw many street money changers in Hong Kong, most of which operated over-the-counter (OTC) businesses using MSO licenses from the Customs and Excise Department and trust licenses from the Companies Registry.

But now, the Securities and Futures Commission (SFC) has introduced the VA OTC license and is open for public consultation, which will conclude at the end of August. Based on the current draft, it's foreseeable that if this VA OTC license is implemented according to current standards, the vast majority of money changers in Hong Kong may be forced to close.

This will significantly close the anti-money laundering loopholes in OTC channels—which has historically been one of the biggest regulatory blind spots in Hong Kong's Web3 ecosystem.

The new regulations require that even street money changers, whether chain or single, must have two responsible officers (ROs) with cryptocurrency experience. Such talent is extremely scarce, let alone two. You must also meet the minimum registered capital of HK$5 million, with at least HK$3 million in cash, and sufficient funds to cover operating expenses for the next 12 months. If expenses exceed HK$5 million, additional reserve funds must be maintained.

This high threshold is clearly unaffordable for ordinary small businesses, so many small OTC locations may exit the market.

It's clear that Singapore isn't the only one raising regulatory barriers; Hong Kong is also gradually tightening them, albeit through different approaches—one is directly clearing the market, while the other is raising the threshold to encourage compliance.

In summary, while both jurisdictions are facing the same international regulatory pressure, their attitudes and strategies are completely different. Hong Kong continues to strive to strike a balance between regulation and industry.

The Global Stock Tokenization Trend: Regulatory Challenges and Hong Kong's Institutional Dilemma

Colin: Next, let's discuss another topic you may also be interested in: the recently popular RWAs (Real World Assets) and stock tokenization. This area of activity is currently very hot in the US, with numerous startups emerging. For example, the partnership between Kraken and xStocks, and especially Robinhood's entry into the pre-IPO stock tokenization market, have garnered significant attention. Stock tokenization happens to be one of your areas of expertise. However, Hong Kong seems to be facing some institutional challenges. A few days ago, we interviewed Councillor Yau (Hong Kong Legislative Council member Darwin Chiu), and Xiao Feng (Chairman and CEO of HashKey Group) was very interested in this topic and actively participated in the discussion. They believe that due to legacy regulations following the stock market crash, Hong Kong stocks can only be traded on the Hong Kong Stock Exchange, completely blocking the path for stock tokenization. What are your thoughts on the development prospects of RWAs and stock tokenization in Hong Kong? Zheng Di: Yes, there are currently three main approaches to stock tokenization in the market: Robinhood, Gemini, which is collaborating with Dinari, and Kraken, which is collaborating with xStocks. Robinhood's approach is completely compliant and flawless. However, the first phase of its launch wasn't actually a stock token, but rather a centralized CFD (Contract for Difference), operated under its MiFID license registered in Lithuania. This CFD was traded on an exchange and couldn't be transferred on-chain.

In contrast, the stock tokens offered by Dinari and Kraken are 1:1 transferable on-chain. Robinhood's product is essentially a virtual asset, lacking a physical mapping to the stock. While they do hold these stocks on behalf of others in the US, these underlying shares aren't collateral for the CFDs, so there's no 1:1 mapping and, therefore, no strict regulatory oversight. This structure allows Robinhood to claim "I'm the buyer's counterparty," holding the underlying shares merely as a hedging tool, not as an endorsement of the CFDs. Consequently, regulatory pressure is relatively minimal.

However, the situation with Dinari and Kraken is more complex. They conducted KYC on their exchange-traded platforms, which was not a problem. However, once users transferred their tokens to the blockchain, there was no guarantee that US users wouldn't purchase them, thereby circumventing SEC oversight and taxation. While they technically block US users, the on-chain system is an open one and cannot completely prevent abuse. This presents a compliance loophole in the current structure.

Furthermore, SEC Commissioner Hester Peirce, known as "Crypto Mom," has previously stated that even if tokenized assets are merely income rights without voting rights, they are still securities. If securities trading is to be offered to retail investors, it must be done on a licensed stock exchange, such as Nasdaq or the NYSE; Coinbase is not permitted.

If such trading is to be offered on-chain, it must be for accredited investors. This is very similar to the situation in Hong Kong—the system established after the Hong Kong stock market crash allows only the Hong Kong Stock Exchange to monopolize Hong Kong stock trading. Regardless of whether stocks are on-chain or not, stock trading can only be conducted on the Hong Kong Stock Exchange. This essentially blocks any potential path for promoting stock tokenization in Hong Kong.

However, a few days ago, news broke that SEC Chairman Paul Atkins is considering whether to grant some sort of exemption for stock tokens trading on-chain. If this exemption were to be implemented, it would be a major breakthrough. Currently, Coinbase and Gemini (partnering with Dinari) are actively negotiating with the SEC. Without an exemption, Peirce's statement is practically a "ban"—if even she objects, the entire US market is essentially doomed.

But if Atkins does grant an exemption, will other countries' SECs follow suit? It's still unknown, but if the US takes the lead in relaxing regulations, it would open the door to global tokenization, undoubtedly a huge leap for the industry.

The EU faces a similar problem: if the US SEC doesn't allow stock tokens to be freely traded on-chain, European regulators could also use this as an argument against Gemini and Kraken's approach, especially since on-chain withdrawal mechanisms would touch upon a cross-border regulatory gray area.

I used to be quite pessimistic, but seeing the news that the SEC might be relenting, I think things might be turning around. The key lies in whether the exemption can actually be implemented and how the specific scope of the exemption is defined.

Robinhood's current first phase—pure CFDs with underlying stock hedging—is compliant and secure, but not on-chain. They clearly hope to enter the second phase, achieving true on-chain stock tokenization. Whether this is feasible depends entirely on Atkins' subsequent statements.

So, overall, stock tokenization is currently at a critical juncture in the global regulatory game. Once the US loosens its grip, whether Hong Kong can simultaneously reform and remove the institutional barriers of the Hong Kong Stock Exchange will also warrant continued attention.

The Rise of RWAs: Differences Between the Hong Kong and US Markets and Future Development Opportunities

Colin: Let's talk more about RWAs, specifically the development of RWAs in Hong Kong. You're also working in this area. What are some promising market opportunities worth watching?

Zheng Di: I believe there are significant differences in the development of RWAs in the US and Hong Kong. The primary asset class for RWAs in the English-speaking world isn't money market funds, but private debt. The advantage of private debt is that it doesn't require market price tracking, resulting in stable prices, making it popular among macro hedge funds and fixed-income funds. As long as they don't go bankrupt, they can consistently generate returns, which may be why they are the largest category of RWAs.

Currently, the mainstream assets in US RWAs are government bonds and money market funds. Globally, there are approximately $7.3 billion in blockchain-based money market funds, including $2.8 billion in BlackRock's BUIDL. In contrast, while non-standard assets such as real estate and infrastructure have also been put on the blockchain, they are not mainstream.

In Hong Kong, on the other hand, compliant RWAs for non-standard assets may become mainstream. For example, the Hong Kong government's 2.0 policy document mentions projects like solar panels and charging stations, assets rarely seen in the US market, reflecting significant strategic differences between the two regions.

However, with the broader trend of "everything on the blockchain," the market potential is enormous. In February of this year, Michael Saylor (MicroStrategy co-founder) stated during an SEC interview that, excluding Bitcoin, the total market capitalization of on-chain assets could grow from the current $1 trillion to $590 trillion. This enormous potential is the primary driving force behind Ethereum, Solana, and the company behind them, MicroStrategy.

However, Hong Kong and the US face a common issue—liquidity in the secondary market. Hong Kong currently does not allow the free transfer of RWAs in the secondary market. Even if assets can be legally on-chain, their value will be difficult to unlock without circulation. For example, whether domestic or foreign assets, if placed in a BVI (British Virgin Islands) or Cayman Islands fund structure and then tokenized, may lack liquidity. In particular, domestic assets seeking to liquidate abroad require a QDLP (Qualified Domestic Limited Partner) quota.

If this liquidity issue can be resolved, it will open up a vast market. Many institutions are currently researching solutions. In the US, some on-chain money market funds can already be transferred on a whitelisted basis, but this practice is still rare. Once implemented, it will be a major step forward in bringing everything to the blockchain.

Hong Kong is currently focusing on the on-chain transfer of money market funds (TMMFs), particularly within the accredited investor zone of licensed exchanges like HashKey Pro. If successful, this would be the first time such transfers have been achieved globally within a compliant framework, a groundbreaking achievement.

However, key issues remain, such as investor protection mechanisms. If an RWA token is transferred to the wrong address or stolen by hackers, there is currently no compensation mechanism. Providing insurance support for these tokens is a hurdle before regulatory action is taken.

Nevertheless, the overarching trend is clear: bringing everything to the blockchain is the future. The SEC recognizes the complexity of the current STO (Security Token Offering) process and is working to streamline it. SEC Chairman Atkins has stated that the Trump administration's call for the US to become the capital of cryptocurrency is meaningless if even retail investor participation is impossible. Currently, only four STO projects have passed the Reg A compliance process, demonstrating its complexity.

Therefore, the SEC aims to introduce a simplified, low-barrier-to-entry STO issuance process. Michael Saylor also emphasized that if the United States hopes to become a leader in the digital economy, it must address regulatory barriers and enable the market to grow from $1 trillion to $590 trillion. Results may emerge in the next two to three years, with a major breakthrough possible as early as next year.

Whether Hong Kong will follow suit remains to be seen. I believe technology is no longer the issue; the core obstacle is regulation. The key lies in finding innovative solutions to overcome policy bottlenecks.