Diverging Paths in Stablecoin Development: Regulatory-Driven vs Industry-Led Approaches

The future of stablecoins is unfolding in markedly different ways across the Pacific, reflecting contrasting strategic approaches between regions.

In mainland China, stablecoin discussions have gained momentum following remarks by People’s Bank of China Governor Pan Gongsheng at the 2025 Lujiazui Forum. He acknowledged that blockchain and distributed ledger technologies are driving the development of central bank digital currencies and stablecoins, while noting the regulatory challenges these innovations present. Meanwhile, Hong Kong is preparing for the implementation of its Stablecoin Ordinance on August 1, prompting numerous financial institutions and tech giants to accelerate their entry into the crypto market:

– Ant Group announced plans to apply for a stablecoin license on June 12
– Logistics technology firm Yutta revealed plans to launch its bitcoin-pegged stablecoin ‘RHKD’
– JD.com Chairman Richard Liu outlined ambitions for global stablecoin licensing to revolutionize cross-border payments
– Yiwu Pay, operated by China’s largest small commodities market operator, expressed interest in stablecoin applications

The stablecoin market has surpassed $250 billion in supply, with Ethena growing to nearly $6 billion since launch. Tether and Circle maintain market dominance with 86% combined circulation, while over $120 billion in US Treasuries now back stablecoins.

This divergence represents two parallel development models in the global stablecoin race: one driven by regulatory frameworks and another by industry adoption. The US approach, exemplified by Circle, focuses on mainstream financial integration through regulatory compliance. After facing setbacks in 2022, Circle’s path forward became clearer with supportive US policies like the GENIUS Act.

In contrast, Hong Kong’s model, represented by JD Coin Chain, emphasizes business-to-business applications. JD’s strategy leverages its supply chain advantages to address specific pain points in cross-border trade rather than competing in consumer payments. The company has begun testing HKD-pegged stablecoins and plans expansion into other currencies.

While Circle aims to become a foundational digital cash protocol for the internet economy, JD envisions a closed-loop trade ecosystem that could potentially include offshore RMB stablecoins. Both approaches face challenges: industry-led models must withstand competition from universal protocols, while regulatory-driven solutions need to demonstrate practical applicability.

As this monetary evolution continues, key questions remain about which approach will ultimately shape the future of digital financial infrastructure.

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