The global status of stablecoin regulation: What should MSO and VASP licensees pay attention to?

StablecoinBusiness is subject to issuance, reserve, redemption, trading platform, brokerage or exchange, hosting, pay, Separate analysis of remittance and promotion. Hong Kong MSO only covers approved money services, The China Securities Regulatory Commission’s VASP system mainly targets virtual asset trading platforms, The issuance of fiat currency reference stablecoins is subject to the regulatory supervision of the Hong Kong Monetary Authority.

Current status and trends of global stablecoin regulation

EU MiCA has established rules for asset reference tokens and e-money tokens. Hong Kong’s Stablecoin Ordinance will be implemented in August 2025, The Hong Kong Monetary Authority is responsible for designating stablecoin issuers for licensing, covered reserves, redemption, governance, Risk management and AML/CFT requirements; Can no longer be described as just a sandbox or advisory phase.

Challenges for MSO licensees: Transformation from traditional payments to digital assets

Many Hong Kong MSO licensees carry out cross-border payment business, Start introducing stablecoins as a means of settlement, to improve capital flow efficiency. However, This raises compliance level complexities:

Source of Funding (SoF) Review: When fiat currencies are exchanged for stablecoins, How to ensure that the source of funds is legal? This places extremely high demands on MSO’s KYC (due diligence) process.
Regulatory classification: MSO YuHong Kong Customs and Excise Departmentsupervision; Stablecoin issuance, trading platform, exchange, Escrow or payment may respectively involve the HKMA, Securities Regulatory Commission or other systems, Must be judged by function.
Technology and financial crime risks: On-chain analysis, Wallet screening, Specific requirements for Travel Rule and Transaction Monitoring depend on the role, client, Products and applicable rules, “Strong on-chain monitoring” should not be written as a unified legal threshold for all MSOs.

Before changing the business, you should start from the product, client, area, Funding and Virtual Asset Control Rights Reassessment Licensing and AML/CFT Liability. Hong Kong Huitong can assist with data sorting, However, there is no guarantee that regulatory issues or licensing implications will be avoided..

VASP licensee: Compliance’s “deep water zone”

Virtual asset trading platform, Escrow or transfer services, Travel Rule, Customer due diligence and transaction monitoring may apply; The scope of obligations and information thresholds must be confirmed according to Hong Kong’s current rules and transaction roles.. Stablecoins are not the “core asset” of every VASP, FATF information cannot replace Hong Kong laws.

How does Hong Kong Huitong support you?

Hong Kong Huitong can help organize stablecoins according to the agreed scope, Business information of MSO and virtual asset system, Application documents and compliance process. When involving independent legal advice or professional assurance, The professionals providing the services and their scope should be separately confirmed. Specific support includes:

Business and Regulatory Matrix: Help organize the subject, Function, client, Funding and virtual asset flows; FATF guidelines cannot ensure offshore structures or cross-border operations are compliant everywhere.
Application documents: Can assist MSO, Application materials for stablecoins and applicable virtual assets; Different systems have different personnel positions, MSOs should not apply unified RO terminology.
Bank information coordination: Can assist in organizing account opening instructions according to the contract; The bank independently decides whether to accept, Open and maintain an account, Channel resources cannot guarantee results.

Conclusion: Embrace compliance, Win in the future

Stablecoin-related companies should continue to check regulatory responsibilities based on actual functions and jurisdictions. Professional consultants available to assist with research and data preparation, But policy risks cannot be eliminated, Ensure market access or enhance competitiveness.

If you are in the MSO Compliance Practice, VASP license application, Or have any questions about setting up overseas financial structures?, Hong Kong HuitongReady to provide you with accurate, Confidential and professional consulting services. let us join hands, On the basis of compliance, Build a stable global financial landscape.

FAQ (FAQ)

ask: Can holding an MSO license automatically allow me to operate a cryptocurrency exchange business?
answer: Cannot operate automatically. Stablecoin or other virtual asset activities are subject to issuance, platform, brokerage or exchange, hosting, pay, Separate analysis of remittance and promotion, May involve the Hong Kong Monetary Authority, Securities Regulatory Commission, Customs or other systems; Not all require an additional VASP license.

ask: How to effectively reduce anti-money laundering (AML) risks in stablecoin transactions?
answer: Risk-based customer and wallet due diligence should be used, Sanctions Screening, Transaction monitoring, suspicious transaction report, Logging and Travel Rule Control. tool, Thresholds and information exchange obligations are determined by specific roles and applicable Hong Kong rules.

Application and Compliance Points: The global status of stablecoin regulation

The global status quo of stablecoin regulation must be split by function: Fiat currency deposit, Currency exchange, Broker matching, trading platform, hosting, transfer, Token issuance and promotion to local customers, Different systems may be triggered separately. Only look at the company’s registered place, Unable to complete license plate judgment.

Things to prepare and keep checking

Stable currency business needs to be issued separately, reserve, redemption, hosting, Brokerage and payment purposes; The same token may trigger payments in different regions at the same time, electronic money, Virtual assets and securities rules.
List actual functions and funding/asset control rights first: Who receives fiat currency, Who controls the private key, Who matches orders, Who decides to list the currency?, Who promotes to local customers.
take the license plate, corporate entity, Bank/payment account, Custodial wallets and technical systems are drawn in the same architecture diagram, Label data, Cross-border flows of funds and virtual assets.
Compliance design should cover customer and wallet risks, Sanctions and on-chain analysis, Travel Rule, market manipulation, Asset segregation, Key management, network security, Incident response and complaints.
Registration should be avoided in publicity, Registration or self-regulatory organization membership is described as a complete exchange license; Scope of licenses in each jurisdiction must be verified individually.

Costs involved, capital, time limit, When personnel qualifications or cross-border business scope, Please refer to the legislation published by the competent authority at the time of submission, Forms and guidelines are subject to.

References: Hong Kong Monetary Authority: Regulatory system for stablecoin issuers (English), Hong Kong electronic legislation: "Stablecoin Regulations", Hong Kong Securities and Futures Commission: Virtual asset trading platform operator, Hong Kong Customs and Excise Department: Supervision of money service operators.

learn more: Hong Kong VASP virtual asset service provider license, Hong Kong legal currency stable currency issuer license (FRS), Full analysis of Hong Kong VASP license 2026 application requirements: SFC latest regulatory framework.