On May 21, the second when the Hong Kong Legislative Council passed the Coin Bill in the third reading, the comments in the crypto trading group next door went completely crazy:
"The license era has officially begun, and small players have no chance to play!"
"Rush to issue stablecoins now? Don't rush if you are not strong enough!"
"PayFi is the real gold mine, if you don't do it now, there will be no soup!"
Noise, anxiety, and excitement are intertwined. But the real Web3 veterans are unusually calm at this moment. They know that the passage of the regulations is not the end, but the moment when the new rules of the game are fired. When those giant stablecoin issuers began to line up to apply for the "Hong Kong Identity Card", a deep and quiet wealth restructuring drama around the stablecoin ecosystem has just begun.
Entrepreneurs, don't just watch the giants fight, open your eyes and look at their feet - there are countless new tracks cracking there, waiting for you to grab a spot and dig for gold!
Stablecoin "card game": hell mode is on, novice village is closed!
Let's be honest: if you are still thinking about "issuing a stablecoin in Hong Kong and getting rich overnight", I advise you to give up this idea as soon as possible. This track has been locked into a "krypton gold player exclusive copy", what is the specific difficulty? Let me count for you:
(I) Sandbox players: the "chosen ones" who have been ahead for two years
The regulatory sandbox of the Hong Kong Monetary Authority is like a "stablecoin preschool". As early as two years ago, a group of "top students" were recruited for training, such as JD's stablecoin project and Yuanbi's stablecoin project. These players have polished the system development, compliance process, and risk control system in the sandbox. Once the regulations are implemented, they directly "graduate" with licenses, which is equivalent to being two laps ahead of the newcomers. How can you, a small team that has just entered the market, compete with them? They have written tens of thousands of lines of code, and you are still studying how to pass the compliance review. This gap is greater than the gap between the top scorer in the college entrance examination and the poor student.
(II) Devil’s Clause: Specially for all kinds of “garage entrepreneurship” fantasies
The “sufficient financial resources” written in the regulations are no joke. For example, if you want to issue a stablecoin in Hong Kong, the registered capital alone must be 25 million Hong Kong dollars, and you must have proof of sustained profitability - this one clause can block 99% of grassroots entrepreneurs. Not to mention “setting up a local physical company”, you have to rent an office in Hong Kong, hire a compliance team, and support technical personnel, and the cost alone is several million per year. This is not entrepreneurship, it’s clearly a “money-burning competition”! Think about the days when USDT could start in a garage, which are long gone. Now it’s a “financial aristocratic game”, and you really don’t touch it if you don’t have a lot of money.
(III) Supervision is so detailed that it can lead to "water meter checking".
In the past, when issuing stablecoins, some "sexy operations" might be done secretly, such as holding on to insufficient reserves, but this is no longer possible. The regulations require that reserve assets must be 100% equal, and only highly liquid assets such as cash and short-term government bonds can be purchased. Want to use stocks or real estate to make up for the number? No way! What's more terrible is that the custodian and the issuer must be strictly separated, and the audit must be real-time and transparent - to put it bluntly, every penny of your money must be put on the table for supervision to keep an eye on, and even the two decimal places cannot be wrong. If you don't have a professional financial team and technical system, problems will be found out in minutes, and fines are light, and you may even have to face lawsuits.
(IV) Policy risks are more stimulating than currency speculation, and ordinary people cannot afford it
Stablecoins involve monetary sovereignty. How can the Hong Kong government issue licenses casually? In the next few years, it will definitely be "pilot first, steady progress", and only a few companies may be approved each year. The fierce competition is comparable to "thousands of troops crossing a single-plank bridge". Moreover, policies may change at any time. The business allowed today may be tightened tomorrow. You are a small team that has worked hard for a year, but in the end you didn't get a license, but you burned all the money. What's the point?
Sobering agent for entrepreneurs: Small and medium-sized enterprises and start-up teams can basically give up completely and stop fantasizing about becoming Hong Kong's stablecoin issuers. This track is a battleground prepared for giants who are not short of money, people, and political and business connections. But! Don't be discouraged! The real gold that belongs to entrepreneurs is hidden in the ecological niche outside the "license fence" built by the giants!
Niche Gold Digging Guide: Five core tracks, there is always one suitable for you
Since the road of issuing coins is not feasible, let's change our thinking: be a "shovel seller" for those who issue coins, and be a "road builder" for those who use stablecoins. The Hong Kong regulations actually draw a very clear boundary: issuing coins requires a license, but the service scenarios around stablecoins are all open. I have sorted out five major compliance opportunities for everyone, and there is always one that can suit your appetite.
(I) Core Track 1: PayFi Infrastructure - Earn Money from "Stablecoin Circulation"
This is definitely the "main battlefield" for small and medium-sized teams. Why? Because the regulations clearly state that "the development of stable currency payment and clearing systems is encouraged", and the market demand is so huge that it is exploding. To put it bluntly, the giants are responsible for issuing currencies, and we are responsible for making the currencies "flow", just like WeChat Pay and Alipay do not issue currencies, but make a lot of money by relying on payment interfaces. How to play it specifically? 1. Cross-border payment: Let foreign trade bosses say goodbye to the pain of "waiting for money for three days" How pitfalls are traditional SWIFT transfers? A cross-border remittance takes 3 days to arrive, and the handling fee is ridiculously high, especially for small and medium-sized foreign trade companies. The exchange rate loss alone is enough to make a pot of money. But using stablecoins is different: USDC transfers arrive in 3 seconds, and the handling fee is less than 10% of the traditional method.
For example: suppose there is a boss doing cross-border e-commerce, who has millions of US dollars in turnover every month. If he uses traditional methods to transfer money, he will spend more than 20,000 yuan in handling fees every month, and he is often urged by suppliers because of the slow arrival of funds. If he is given a stable currency payment channel, the handling fee can be saved by 80%, and the funds will be received in real time. How can he not be happy?
2. Merchant settlement: From milk tea shops to chain brands, they all need "seconds to arrive"
Now many merchants are actually using USDT to collect payments, but they are all sneaky. After the regulations are implemented, a compliant stable currency payment system is a rigid demand.
For example: milk tea shops, tea restaurants, and chain retailers all over the streets, don’t they want to collect money faster and at a lower cost? You develop a payment platform/tool that allows them to settle stablecoins such as USDC and FDUSD in real time. The handling fee is 80% lower than that of traditional POS machines or payment gateways, and the funds are credited in seconds. How can the bosses not love you? 3. Multi-chain clearing: Become the "UnionPay of the Coin Circle" and make money from traffic without doing anything One of the biggest pain points in the coin circle now is that "chains are not connected": USDC on ETH, USDT on Solana, DAI on Polygon... What if merchants want to collect HKD? What if users want to make cross-chain payments? At this time, a "multi-chain clearing hub" is needed, just like the UnionPay system between banks, to connect the stablecoin liquidity of different public chains and make stablecoins truly flow. The value is self-evident.
(II) Core Track 2: Compliance "Arms Dealers", "Selling Tools" to Licensed Bigwigs
The stricter the supervision, the greater the demand for compliance services. Just like when the e-commerce platform emerged, a large number of agency operations and quality inspection service companies were born, the compliance needs of stablecoins will also breed a trillion-level market. What are the specific opportunities?
1. Anti-money laundering tools: Make on-chain transactions "transparent"
Regulators require that stablecoin issuers must monitor transactions in real time, and once a suspicious address is found (such as a connection with an exchange hacker), it must be reported immediately. At this time, an "on-chain black and white list screening tool" is needed, such as developing an API to connect to the data of major public chains to help issuers automatically identify risky addresses. For example: if a certain address suddenly transfers 100,000 USDC and then disperses it to 100 new addresses, your system can automatically trigger an early warning, indicating that it may be money laundering. This tool is charged annually, with one customer receiving 100,000 to 200,000 per year, and 10 customers can support a small team. 2. Audit service: "physical examination" for stablecoins In the past, USDC issued a reserve report every month, and the market response was very good, because users need to know whether their money is really guaranteed. Now Hong Kong regulations require issuers to disclose reserve information regularly, which requires a professional audit team. You can set up a "stablecoin audit firm" to help issuers do real-time reserve verification, such as checking whether their bank account balance matches the number of stablecoins in circulation, and issue a transparent report. This service charges a high fee and requires professional qualifications. Once you get a few big customers, you can establish industry barriers.
3. Regulatory Technology (RegTech): Make Compliance "Automated"
Many small and medium-sized issuers do not have the ability or need to develop their own compliance systems. At this time, you can make a "compliance report generator", such as accessing their financial data and on-chain transaction data, automatically generating reports that meet the requirements of the HKMA, and submitting them with one click. Just like the current financial and tax software, simplifying the complex compliance process into "one-click operation", such tools charge hundreds to thousands of Hong Kong dollars per month, and can make a lot of money if the number of customers is large.
(III) Core Track 3: Cross-chain Bridging - Being the "Ferryman of the Stablecoin World"
Multichain is the general trend. What follows is the explosive growth of cross-chain demand for stablecoins. Especially in:
When USDC lies safely on Ethereum, USDT is having fun in TRON, and the tea restaurant owner in Hong Kong only recognizes HKD... A safe, fast, and low-slip stable currency cross-chain bridge has become a rigid demand among rigid demands!
Opportunities: Develop secure, efficient, low-slippage cross-chain protocols or services focused on stablecoins. Focus on supporting mainstream public chains in the Hong Kong market: ETH, Solana, TON, Polygon, etc.
Technical life and death line:Safety! Safety! Still safety! The tragedy of hundreds of millions of dollars being stolen from the Nomad Bridge overnight is still vivid in our minds. Your bridge must be armed to the teeth: consider introducing advanced cryptographic technologies such as zero-knowledge proof (ZK) for security verification, and none of them can be missing, such as multi-signature and decentralized oracle network. Safety is 1, and everything else is the 0 behind it.
Don’t cross the legal red line: When designing the mechanism, it is necessary to strictly guard against it to avoid being identified by regulators as a disguised issuance of coins (such as issuing assets out of thin air through a bridge) or causing multi-chain inflation problems. This requires close collaboration between the legal and technical teams.
(IV) Core Track 4: Stablecoin Asset Management - Let the "lying flat" stablecoins "give birth"
If the stablecoins in the hands of users are just left there, they will have no income like cash, but the Hong Kong Stablecoin Ordinance does not allow the issuer to directly pay interest. What should I do? At this time, asset management services are needed to help users make money from stablecoins: 1. Access DeFi protocols: Earn the difference between lending and borrowing interest You can build a platform to connect users' stablecoins to lending protocols such as Compound and Aave. After deducting your service fee from the interest earned by the user, the rest belongs to the user. For example, Compound's current USDC lending rate is 4%, and you charge a 1% service fee. Users make a net profit of 3%, which is much higher than bank demand deposits. But remember: it is strictly forbidden to promise to protect the principal! Risks must be indicated in a prominent position on the page, such as a large title: "DeFi is risky, investment should be cautious", otherwise once the market plummets, users may sue you for losses.
2. Real-world asset (RWA) returns:Invest in government bonds and real estate
In addition to DeFi, stablecoins can also be invested in real-world assets, such as U.S. Treasury token products. Users use USDC to purchase "Treasury bond tokens" and receive interest on time, and you charge management fees from them. This model is more compliant because government bonds are low-risk assets with high regulatory acceptance. There are many asset management companies in Hong Kong that are good at RWA. You can work with them to do front-end sales and compliance docking.
Circle (through its asset management branch), Maple Finance (focusing on institutional lending), Ondo Finance (RWA pioneer) and other teams are already exploring this path. With its mature financial market and open regulatory attitude, Hong Kong is fully equipped to implement this model in a compliant and large-scale manner. It is suitable for teams that are proficient in financial engineering, familiar with structured products, and can play with compliance frameworks.
(V) Core Track 5: Reserve Asset Management - Being the "Stablecoin Steward"
If a stablecoin issuer wants to obtain a license or renew a license, it must have top-level custody, management and risk control arrangements for its reserve assets (cash, short-term government bonds, and possibly a small number of highly rated RWAs). This means:
Core logic: Don't build a giant ship (issue currency), but be the indispensable "ballast stone" and "escort ship" of the giant ship! Hong Kong has Asia's top financial custody, clearing, and asset management ecology, which is the natural home advantage of local professional service institutions.
The table is open, which chair do you choose?
The implementation of the Hong Kong Stablecoin Ordinance is by no means the end of the story. It is more like a clear and powerful shot that Hong Kong took the lead in the global stablecoin regulatory competition. While New York legislators are still arguing and Singapore's framework is still being patched up, Hong Kong has already revealed clear, predictable rules that are in line with international standards - this in itself is a huge and scarce institutional dividend!
Stop staring at the top of the pyramid of "issuing coins", and look at the ecological niches around you: some people make tens of millions a year by making payment interfaces, some people are valued at over 100 million by selling compliance tools, and some people get top institutional investment by cross-chain bridges. The game of Hong Kong's stablecoins has begun. The giants are the dealers and issue coins, and we ordinary people are just "selling tea and renting chairs next to the dealers", and we can still have a place in this new financial era.
Finally, I would like to give you a word: In the world of Web3, smart entrepreneurs never go head-to-head with giants, but dig their own gold mines in corners that they can't see. In the new era of Web3 where licenses are king, compliance is no longer just a bottom line, but your sharpest and most indispensable ticket! Only by seeing the track clearly and finding the right ecological niche can we strike gold in this round of stablecoin boom led by Hong Kong.
Brian
Joy
YouQuan
Hui Xin