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 crypto, 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, with a transaction volume of US$25.65 million within 24 hours.
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, trading platforms such as Coinbase had already chosen it. Responding to the implementation of the MiCA Act with caution, the decision to delist USDT for EU users was revealed in October 2024.
2025 has already begun. The formal 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 represented by the EU and the United States, what can we see? What is the common law? 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 the EU’s attitude towards crypto assets Disclaimer: We welcome cryptoassets, but they must be used responsibly and securely
About the MiCA Act
Legislative purpose: Ensure that EU legislation on financial services adapts to the needs of today's digital era and future economic development, and promote the active adoption of distributed ledger technology in the financial sector. Transformative technologies within the EU will promote new business activities and models. Together, these new business formats and crypto-assets will bring economic growth and new job opportunities to the EU.
△ Implementation time chart of the MiCA Act Source: ESMA
About Stablecoin
Definition:< /strong>Stablecoin is a crypto-asset defined in the EU MiCA Act, which defines two forms for the crypto-asset industry: Electronic Money Tokens (EMTs) and Asset-Referenced Tokens (ARTs) ), which is equivalent to excluding forms such as algorithm Stablecoin.
Licensing: According to a report by the European Times, Marina Markezic, co-founder of the European Encryption Initiative (EUCI), once said that the MiCA Act Provide a unified regulatory framework through a "license pass" system, allowing companies to operate within the entire trade area after obtaining regulatory permission in a member country.
This means that according to the requirements of the MiCA Act, Stablecoin issuers in the EU market need to obtain an authorization license 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
The United States currently does not have a complete regulatory framework specifically for Stablecoin, but some regulatory bills related to digital assets that have not yet taken effect and are in the legislative process involve the supervision of Stablecoin. Bills worthy of attention include: p>
▶"Financial Innovation and Technology Act of the 21st Century" (commonly referred to as the FIT21 Act): Involves jurisdiction over digital assets including Stablecoin .
For details of the FIT21 bill, please visit:
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 debated in the industry
▶"Loomis-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 Stablecoin ; Requires issuing institutions to set up reserves equivalent 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"
the Lummis-Gillibrand Payment Stablecoin Act
For details, please visit:https://www.congress.gov/bill/118th- congress/senate-bill/4155/text
▶The Clarity for Paying Stablecoins Act (The Clarity for Payment Stablecoins Act of 2023): Establishes issuance standards, reporting requirements, and consumer protection regulations for payment Stablecoins, making it clear that payment Stablecoins are not securities or commodities.
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< /p>
For details, please visit: https://www.congress.gov/bill/118th-congress/house-bill/4766/text
▶ In addition to the above-mentioned bills, New York State in the United States has already passed the New York Financial Services Law (New York Financial Services Law) as early as June 2015. ) released Regulations forVirtual Currency (Part 200 Virtual Currency Regulation), including the well-known BitLicense licensing requirements, Digital asset service providers, including Stablecoin issuers, need to obtain a license to conduct related business 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=I7444ce80169611e594630000845b8d3e&originationContext=documenttoc&transitionType=Default&contextData=(sc.Default
Singapore
According to a report on December 28, 2024, the Managing Director of the Monetary Authority of Singapore (Managing Director) Chia Der Jiun said in an interview with the Business Times: Stablecoin has the potential to become a widely used payment tool and will have a high degree of stability if it is well regulated.
On August 15, 2023, the Monetary Authority of Singapore announced the official release of the Stablecoin regulatory framework, which is applicable to the Singapore dollar or any G10 currency (including the US dollar, euro, Japanese yen, Swiss franc, Canadian dollar, Australian dollar, Stablecoin is a single currency pegged to the British pound, Norwegian krone, New Zealand dollar, etc. (but not the Chinese yuan), aiming to promote the use of Stablecoin as a medium and bridge for trusted digital exchange, and a bridge between currencies and digital ecosystems. p>
Singapore's Stablecoin regulatory framework has set higher requirements for Stablecoin issuers to prevent risks. For example, the requirement to link currency reserves and the number of Stablecoins issued is equal to or greater than 1:1. At the same time, it also imposes requirements on Stablecoin issuers to prohibit business operations, meet minimum asset adequacy, and ensure minimum liquid assets in operations.
The Financial Regulatory Authority of Singapore. Response to the public consultation on the proposed regulatory approach to Stablecoin-related activities
For details, please see:
< em>https://www.mas.gov.sg/-/media/mas-media-library/publications/consultations/pd/2023/response-to-consultation-on-stablecoins-regulation_15aug2023.pdf< /p>
Abu Dhabi
December 5, 2024 The Financial Services Authority of Abu Dhabi Global Market issued the 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 does not belong to payment activities, and it is determined that Stablecoin transactions belong to the type of payment activities.
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) 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, China
On December 6, 2024, Hong Kong, China announced The full text of the Stablecoin Bill. The bill defines Stablecoin and Stablecoin-related activities, sets detailed licensing requirements, and explains regulatory norms. Service providers need 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 Stablecoin Bill
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 countries and regions have adopted different legal frameworks for the supervision of Stablecoin, some common regulatory principles still emerge, as shown in:
Defining Stablecoin basically excludes algorithmic Stablecoin.
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 into the category of encrypted assets (or digital assets) for supervision; the United States Although there is no specific and complete regulatory framework for Stablecoin at the federal level, there are currently different bills involving Stablecoin that are in the legislative process, and there are still obvious inconsistencies in the definition and jurisdiction of Stablecoin; in Singapore, Abu Dhabi, and Hong Kong, China The jurisdiction over Stablecoin is relatively clear.
Compared with the comprehensiveness of the EU MiCA Act, the regulatory frameworks for Stablecoin in the United States, Singapore, Abu Dhabi, and Hong Kong have their own emphasis, which also reflects the markets in each region. There are differences between the development goals of Stablecoin and the current market situation. For example, the United States, Singapore, and Abu Dhabi focus on the supervision of payment applications, while Hong Kong, China 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.