#稳定币

This qualitative assessment from number 28 has shattered all the fantasies about stablecoins in the industry over the past few years.

On the surface, it is a regulatory policy, but in reality, it is a statement about monetary power.

The United States has turned stablecoins into an extension of the digital dollar with the (GENIUS Act). Domestically, this qualitative assessment categorizes stablecoins as illegal.

Both sides are very clear about what they are doing.

01 | “Stablecoins are a form of virtual currency.”

This is not the first time virtual currency has been mentioned, but it is the first time that the authorities have explicitly equated stablecoins with Bitcoin and Ethereum.

In the past few years, many projects have bet on the assumption that “stablecoins are not considered virtual currency.” They believed that as long as there are dollar reserves and no volatility, they could tell a story to regulators.

Now this assumption has completely collapsed. Having reserves is also virtual currency, and stable is also virtual currency.

What does this mean? It means that cross-border payments, supply chain finance, and on-chain settlements are all marked off within the country.

Is this bad news? It certainly is for many teams. But at least we don’t have to guess anymore.

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02 | The world is embracing stablecoins, why is the domestic side going backward?

Pull the timeline to the second half of this year, and you will see a very magical picture.

In July, U.S. President Trump signed the (GENIUS Act). The goal of this act is very straightforward: to formally include stablecoins like USDT and USDC into the U.S. financial regulatory system.

At the same time, what is Hong Kong doing? Launching a stablecoin licensing system.
What is the EU doing? Issuing the world's first compliant license to USDC.
Major banks in Japan and Europe are betting on their own local currency stablecoins.

Then in November, the central bank held a meeting and directly announced: stablecoins equal virtual currency, all illegal.

The world is embracing it, but we are choosing to go backward.

Why is this?

Because the decision-makers see a problem: when all countries are scrambling for stablecoin licenses, it indicates that this thing is no longer just a payment tool, but a new battlefield for currency hegemony.

And the officials do not want the currency hegemony of others to take root here.

Is this choice right or wrong? We do not comment. But as industry practitioners, we must accept this reality.

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03 | The truth about stablecoins: a game about the U.S. dollar

First, let's look at a piece of data.

As of the end of November, the total market value of global stablecoins is about 300 billion U.S. dollars. Among them:

USDT: 184 billion, accounting for 60%
USDC: 75 billion, accounting for 25%
All other stablecoins combined: less than 15%

Two American companies control more than 80% of the global stablecoin market.

Now let's look at a deeper piece of data.
USDT's reserves include over 100 billion U.S. dollars in U.S. Treasury bonds.
USDC's reserves include over 20 billion U.S. dollars in U.S. Treasury bonds.
What does this mean?

It means that every time stablecoins are issued, they are financing the U.S. Treasury.
We thought we were using a 'decentralized digital dollar', but in reality, we are contributing to U.S. Treasury bonds.

Now looking back at 2020. That year, the global stablecoin market value was only 6 billion U.S. dollars. By the end of 2021, this number surged to 150 billion and has now exceeded 300 billion.

Where does this explosive growth come from?
It's not spontaneous from the market, but a result of the shift in U.S. policy. Starting in 2021, the U.S. logic changed: instead of preventing digital currency, it was better to turn digital currency into a digital form of the dollar.

Thus, the core of the (GENIUS Act) in July this year is not to regulate stablecoins, but to confirm that stablecoins are part of the dollar.

Now do you understand why it’s said that it’s not possible in the domestic market?
Because this is not a technical issue, it's a geopolitical issue.

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04 | The shadow of 2015 still hangs over the decision-makers

The central bank's public statements repeatedly emphasize: money laundering, fraud, illegal cross-border transfer of funds.

But if these are just the issues, why not leave a loophole like 'personal possession is legal' as with Bitcoin?

The real concern is much deeper: the life and death of the foreign exchange management system.

Imagine this scenario.

If USDT could circulate legally in the country, anyone could open a wallet to exchange RMB for USDT, and then transfer it on-chain overseas.

Without going through banks, without going through the foreign exchange bureau, without leaving any records.

What does this mean? It means the entire foreign exchange management system would be circumvented.

Do you remember the story from 2015? Under the pressure of RMB depreciation, nearly 1 trillion U.S. dollars flowed out in a year.

What means were used for capital flight back then? Underground banks, trade misreporting, offshore insurance policies. Complicated, slow, and costly.

If there was USDT, none of this would be needed. A mobile wallet solves everything.

The destructive power of the next crisis will be ten times that of 2015.

This is what the decision-makers are truly trying to prevent.

So why is the domestic side vigorously promoting the digital RMB while simultaneously implementing a blanket ban on stablecoins?

Because every transaction of digital RMB is controllable and traceable, but USDT is a black box.

This is the dividing line between the two routes.

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05 | Why can Hong Kong?

On August 1, Hong Kong launched a stablecoin licensing system, and many people feel this is a window period.

Don't be too quick to rejoice.

The core of Hong Kong's stablecoin license is two words: offshore.

What does offshore mean? It means not touching mainland users, not touching RMB, and not allowing domestic funds to have any relationship with stablecoins.

Someone asked: I registered in Hong Kong, with servers in the U.S., only doing technical outsourcing, that should be fine, right?

No, it is not.

The qualitative determination on November 28 has already blocked this path. Who are your users? Where does your traffic come from? Where does your funding flow?

As long as there is one link associated with the domestic market, this project is considered high risk.

Who is Hong Kong's license for? It is for large banks like Standard Chartered and HSBC. They are doing offshore U.S. dollar settlements, serving overseas multinational corporations.

Currently, 80 companies have applied, and the Monetary Authority has said that the first batch will be announced in early 2026, and only a single digit will be able to obtain it.

So don’t put all your bets on Hong Kong.

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06 | Two paths for entrepreneurs

The current situation is very clear.

Path one: completely go overseas
If you want to continue doing stablecoins, you need to be mentally prepared: the entire business chain must be overseas.

It’s not just about registering an overseas entity. Your users must be overseas, your funds must be overseas, and it’s best that your team is also overseas.

Don't think that 'I’m just making a wallet' or 'I’m just making an SDK' can bypass this. Stablecoins are now equivalent to virtual currency; if you provide technology for virtual currency, you bear this risk yourself.

Path two: shift to digital RMB

The digital RMB ecosystem has many opportunities. Payments, wallets, merchant services, application scenarios, and cross-border settlements are all directions clearly supported by the authorities.

As for Hong Kong? You can pay attention, but don’t harbor illusions. That’s for banks to play with, not for entrepreneurs to exploit.

In short, this determination is telling you: this path cannot work domestically.
If you need to go overseas, then go; if you need to transform, then transform. Don’t waste time in the gray area.

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In the long run, this is a protracted struggle over monetary sovereignty, so everyone should be prepared.