How Far Is an Offshore Yuan Stablecoin From Reality? (AI Translation)

【周刊提前读】离岸人民币稳定币还有多远？

Summary

1. Donald Trump's second presidency has greatly influenced the global cryptocurrency industry, with significant emphasis on stablecoins. Multiple economies are implementing strategies such as legislative support for local trade monopolies, defining blockchain standards, and fostering fiat-backed stablecoin ecosystems, sparking an international race to regulate and legitimize stablecoins. Regions including the US, EU, Singapore, Hong Kong, Taiwan, Russia, Japan, Korea, Australia, India, Thailand, Argentina, South Africa, and Nigeria have announced legislative initiatives in this area. [para. 1]

2. According to Deutsche Bank, by 2025 stablecoin transaction volume already surpasses Visa and Mastercard combined, though this is still primarily online crypto activity rather than real-economy payments. Nonetheless, stablecoins are quickly approaching a disruptive scale for traditional payment systems. [para. 2]

3. Stablecoins, defined as privately-issued digital currencies pegged to stable assets like the US dollar or gold, serve as a bridge between digital assets and fiat currencies, providing a stable replayment and settlement tool. Regulatory opinions have shifted; former SEC Chair Gary Gensler likened them to casino chips, while Fed Chair Jerome Powell saw their potential in a properly regulated framework. Under Trump's new presidency, US legislative and regulatory stance has shifted to active engagement, exemplified by the "GENIUS Act" (Guiding and Empowering National Innovation in U.S. Stablecoins Act) which passed the Senate 68–30 on June 17, 2025, and is expected to become law by summer recess. [para. 3][para. 4]

4. Globally, regulators demand stablecoins be strictly backed by sufficient fiat reserves with transparent management and disclosure. Jurisdictions like the EU with MiCA, Singapore's 2023 stablecoin framework, and Hong Kong's Stablecoin Bill (passed in May 2025 and effective August 1) have adopted similar requirements. [para. 5][para. 6][para. 7][para. 8]

5. Major stablecoin issuers, like Circle (issuer of USDC and EURC), benefit from favorable momentum; Circle’s stock price quadrupled in three days after its NYSE debut in June 2025. Related stocks in China’s A-shares and Hong Kong markets also surged. The mainstream model is now single-fiat pegged stablecoins. [para. 10][para. 11]

6. The US "GENIUS Act" notably allows both onshore and offshore dollar stablecoin issuers to operate under US licensing rules, making dollar stablecoins dominant globally (99% of all stablecoins are dollar-backed vs. only 50% of global payments in dollars). Daily stablecoin trading volume regularly exceeds $100 billion, dwarfing Bitcoin and Ether combined, and is a critical medium of exchange in the crypto market, as well as in countries with high inflation. Most dollar stablecoin reserves (about $200 billion) are held in US Treasuries, increasing demand for US debt. [para. 17][para. 18][para. 19][para. 20][para. 21][para. 22][para. 23]

7. Hong Kong’s new law sets the global record for speed in stablecoin regulation, requiring licenses for issuers, strict reserve requirements, routine audits, and adherence to anti-money laundering/counter-terrorism financing rules. Retail users may only hold licensed stablecoins, while professionals can access unlicensed types under KYC restrictions. [para. 27][para. 28][para. 29][para. 30][para. 31][para. 32]

8. Singapore, after the FTX and 3AC crises, tightened on digital token service providers, now requiring those serving only foreign clients to relocate if not licensed by June 2025. This marks a sharp regulatory turn after years of prioritizing innovation. [para. 39][para. 40][para. 41][para. 42][para. 43]

9. Stablecoins’ main use remains digital asset trading and, increasingly, real-world asset (RWA) tokenization and cross-border payments. They offer rapid settlement and low costs compared to traditional banking but also avoid compliance costs, which may rise as regulation tightens. New services include tokenized stocks and funds using stablecoins for investment and redemption. [para. 48][para. 49][para. 50][para. 51][para. 53][para. 54]

10. There is growing discussion in Hong Kong about launching offshore RMB stablecoins, leveraging sizable CNH pools, but actual issuance remains subject to People’s Bank of China approval. Small-scale offshore RMB stablecoins exist but are negligible in market impact. [para. 59][para. 60][para. 61][para. 62][para. 63][para. 64][para. 65][para. 66][para. 67][para. 68]

11. Critics and experts warn of risks: stablecoins may undermine monetary sovereignty, weaken central bank controls, and create new financial stability concerns, especially if under-reserved or leveraged. A dual-tier (wholesale-retail) model is suggested to align stablecoins with traditional monetary systems, reduce risk, and preserve systemic coherence, as seen in UK and Swiss pilots. [para. 72][para. 73][para. 74][para. 75][para. 76][para. 77][para. 78][para. 79][para. 80][para. 81][para. 82][para. 83][para. 84]

12. In summary, global stablecoin regulatory approaches are converging, but national motivations and market structures vary. While dollar stablecoins reinforce US monetary hegemony, China weighs stablecoin development against sovereignty and stability priorities. The regulatory regime is evolving from a technical to institutional competition, with stablecoins rapidly reshaping payment and settlement systems. [para. 3][para. 10][para. 11][para. 18][para. 86]