How China and the Rest of World are Catching Up to US Stablecoin Laws
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How China and the Rest of World are Catching Up to US Stablecoin Laws

Gleb1453

Gleb1453

3 min readSeptember 2, 2025

This summer, the US has enacted the GENIUS Act, its first federal stablecoin law, setting clear rules for payment stablecoins in the US. With this regulatory “blessing”, the tech firms followed fast, with recent news of Stripe and Circle announcing launching their own L1s, dedicated for stablecoin payments. Alongside MiCA, the GENIUS Act makes it apparent that crypto is becoming more and more embedded in the “everyday” financial system. Other jurisdictions now face pressure to catch up.

China

China is reportedly now pivoting sharply from its previous crypto ban. According to Reuters's report, Beijing is preparing to permit yuan-backed stablecoins via Hong Kong’s new Stablecoin Ordinance, effective August 1, 2025. This marks a 180 shift from its 2021 prohibition on trading and mining. This shift stems from China’s leaders' motivation to reduce the reliance of the global economy on the US dollar. But currently, the USD-pegged stablecoins make up most of the $250 billion stablecoin market, while the yuan’s share is currently at just under $2.88m.

Hong Kong 

Hong Kong has taken a leap forward with its Stablecoins Ordinance effective August 1, 2025, a regime that licenses fiat‑pegged stablecoin issuers, mandates full reserve backing, strict AML compliance requirements, and even criminal penalties for unlicensed promotions. Crucially, this opens the door for the offshore yuan stablecoin, positioning Hong Kong as Beijing’s chosen jurisdiction for internationalising renminbi’s role in global finance and efforts to challenge dollar dominance.

EU

MiCA has been in force for over a year now, being one of the first stablecoin regimes, globally. But with the GENIUS Act now in place, USD-pegged stablecoins could see a surge in adoption, hindering hopes of the euro becoming a contender to the digital dollarisation. And so while the US framework explicitly bans CBDCs, and Europe is doubling down on the opposite path, with the ECB accelerating the development of a digital euro to counter the growth of USD-pegged stablecoins. The pilot testing is expected by the end of 2025. The ECB is reportedly currently exploring Ethereum and Solana for the launch of the digital Euro. 

Bahrain

In July 2025, the Central Bank of Bahrain launched its Stablecoin Issuing and Offering Framework, allowing only fully fiat-backed, single-currency tokens (BHD, USD). The regime requires 100% reserves and strict disclosures, making Bahrain one of the most stringent regimes in the Middle East. Dubai’s VARA has previously taken a similar stance, though with more flexible licensing and scope for non-AED and commodity-pegged tokens.

Wyoming 

In August 2025, a month after the GENIUS Act became reality, Wyoming became the first US state to issue a stablecoin. The Frontier Stable Token (FRNT) is backed 102% by Treasuries and cash, and designed for government payments like vendor contracts and instant tax refunds. Built with VISA integration, it will be usable via Apple Pay, Google Pay, and cards, and live across major blockchains. FRNT currently tests a “public option” for stablecoins, but remains in the pilot phase.

UK 

The UK seems to be taking a cautious and apprehensive route. The FCA’s 2025 consultation and HM Treasury’s draft rules frame stablecoins as “money-like instruments” requiring full low-risk backing and redemption at par. UK’s market players see the approach as slow and restrictive. Recently, 30 major crypto firms present in the UK, including Coinbase and Kraken, called for a national stablecoin strategy, warning Britain risks being left behind. GBP-pegged tokens remain negligible, at only circa $627,000 total market cap, roughly 0.0002% of the global market. Without regulatory recognition, market players fear the UK will lose its Fintech talent to the US, EU, Hong Kong, UAE or other early movers.

The ripple effect of GENIUS is just beginning. When even a historically conservative and crypto-agnostic player such as  China is openly exploring stablecoins, the momentum is not optional. GENIUS Act, and previously MiCA, have set the pace, and now every other market will be measured by how it follows.

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