The tightening regulation of USDT in Hong Kong and the mainland's "zero tolerance" governance on stablecoins have jointly triggered a regulatory storm in the cryptocurrency sector. This combination not only reshapes the market structure of stablecoins both domestically and internationally but also clearly presents China's differentiated regulatory approach of "strict domestic regulation + offshore standardization," with specific impacts and deeper logic as follows:
1. Mainland: From "restriction" to "criminal governance", zero tolerance fully upgraded
On November 28, 2025, the central bank led 13 departments to jointly clarify that stablecoins fall under the category of virtual currencies, and related businesses are officially included in the regulatory framework for illegal financial activities—this is the first time at the national level that legal boundaries for stablecoins have been defined. The regulation adopts a "full-chain blockade" strategy: it strictly prohibits the issuance and trading of stablecoins within the mainland, cuts off the relevant funding channels of banks and payment institutions, cleans up the domestic traffic behaviors of overseas platforms, and directly holds liable the entities involved for criminal responsibility. From January to October 2025, the mainland has cracked down on 342 criminal cases related to stablecoins and intercepted 12,000 suspected illegal transactions, with the amount involved reaching 4.6 billion yuan, completely curbing the chaos of stablecoins becoming tools for money laundering and illegal cross-border fund transfers. At the same time, this has also cleared obstacles for the promotion of the digital yuan, with the scale of cross-border payments in digital yuan exceeding 10 trillion yuan by 2025, accelerating its implementation in scenarios such as cross-border trade and supply chain finance.
2. Hong Kong: Under strict regulation, "blood transfusion" of USDT to build a compliant ecosystem
With the formal implementation of the stablecoin regulations in August 2025, Hong Kong has entered an era of strong regulation on stablecoins. Due to the failure of the issuer Tether to meet licensing requirements, Hong Kong has fully restricted retail investors from participating in USDT trading, allowing related businesses only for professional investors. As of December, no stablecoin institutions in Hong Kong have successfully obtained licenses. The Monetary Authority of Hong Kong has set high thresholds to filter compliant entities: non-bank institutions must have a paid-in capital of 25 million Hong Kong dollars and require stablecoin issuers to have 100% high liquidity reserves (such as cash, short-term government bonds, etc.), with independent custody and support for redemption at face value. The core regulatory direction is clear, aiming to guide stablecoins to serve the real economy. So far, companies like Caesar Travel have implemented applications that enable real-time conversion of stablecoin consumption by overseas tourists into RMB, improving settlement efficiency by 90% compared to traditional methods.
3. Market Structure: Intensified differentiation between domestic and foreign, funds flowing to compliant channels
The mainland's "zero tolerance" policy has directly led to a significant contraction in the trading scale of stablecoins within the region. The previous dominance of USDT in the over-the-counter trading of virtual currencies, accounting for 90%, has been thoroughly disrupted. Existing funds have turned to digital yuan or compliant offshore financial instruments. Meanwhile, Hong Kong has successfully attracted international institutions like Sequoia Capital through a "blood transfusion" style of regulation on USDT, with clear rules and strict standards for selecting quality entities, injecting new vitality into the compliant virtual asset ecosystem.#加密市场观察 #美股2026预测 