Comparison of Global Web3 Regulatory Policies in Hong Kong

Author: Mask

Web3 technology, centered around blockchain, is reshaping the global financial, social, and business ecosystem through innovative models such as decentralization, smart contracts, and encrypted assets. With the rapid development in this field, the financial risks, data security challenges, and legal voids it brings have prompted regulatory authorities in various countries to take active measures. The United States, the European Union, Singapore, and Hong Kong, as key hubs for the global development of Web3, have each established distinctive regulatory frameworks.

This article will conduct an in-depth analysis of the Web3 regulatory policies in these four major jurisdictions from the perspectives of regulatory agencies, policy frameworks, core rules, and market impacts, revealing their commonalities and differences, and exploring the future direction of global regulatory coordination.

United States

"Law Enforcement First" Model Under Securities Law

1. Bullish Regulatory System and Policy Trends

The regulation of Web3 in the United States exhibits typical characteristics of "multi-head regulation," involving multiple federal agencies such as the Securities and Exchange Commission ( SEC ), the Commodity Futures Trading Commission ( CFTC ), and the Financial Crimes Enforcement Network ( FinCEN ), along with various state regulatory agencies.

On January 20, 2025, after taking office, Trump appointed Mark T. Uyeda as the acting chairman of the SEC and Caroline Pham as the acting chairman of the CFTC, aiming to provide a more stable and predictable policy environment for the cryptocurrency industry, achieving a transition from "regulation through enforcement" to a "clear regulatory framework."

On January 23, 2025, Trump signed an executive order titled "Strengthening America's Leadership in Digital Financial Technology," aimed at promoting the United States' leadership in the fields of digital assets and financial technology and supporting the responsible development of the cryptocurrency industry.

The executive order proposes the establishment of a "Presidential Digital Asset Market Working Group" to explore federal regulatory measures for stablecoins and relevant plans for a national digital asset reserve, while explicitly prohibiting the "establishment, issuance, circulation, or use" of central bank digital currencies (CBDC).

2. Establishing a Strategic Bitcoin Reserve

On March 6, 2025, Trump signed an executive order "Building a Strategic Bitcoin Reserve and a U.S. Digital Asset Inventory" and held the first cryptocurrency summit at the White House on March 7, demonstrating his commitment to making the United States a "global crypto capital." However, on March 7, the price of cryptocurrencies continued its recent decline, and the price of bitcoin fell rapidly, falling short of market expectations.

On January 23, the Senate Banking Committee established a Digital Assets Committee, chaired by Senator Cynthia Lummis, reflecting the importance placed on the regulation and development of the cryptocurrency sector.

In May 2025, there were reports that the stablecoin legislation was advancing and the digitization of the dollar was nearing a turning point. The Trump team may support the inclusion of legal stablecoins (such as USDC) in the national economic strategy. If realized, stablecoins will become the "commercial hub" of the federal government's digital financial system, rather than a competitor to Bitcoin.

3. Characteristics of State-level Regulation

Outside the federal regulatory framework, states have also developed their own distinctive regulatory models:

• New York State's BitLicense is the most influential cryptocurrency asset license, requiring businesses to adhere to strict consumer protection and anti-money laundering compliance requirements.

• Wyoming has adopted a relatively friendly regulatory approach, recognizing cryptocurrencies as money through a series of laws and allowing banks to provide digital asset custody services.

Europe

Attempts at Harmonization of Supervision under the MiCA Framework****

1. MiCA: A Unified Regulation for the European Crypto Asset Market

The European Union has (MiCA) become a "pioneer" in global Web3 regulation through the Cryptoasset Market Supervision Act. The regulation, which will come into force in 2024, sets out comprehensive rules for cryptoasset issuance and market trading:

• Categorical supervision: Divide crypto assets into electronic currency token (EMT), asset reference token (ART) and utility tokens. Non-fungible tokens (NFT) and central bank digital currencies (CBDC) are not regulated by MiCA.

• Licensing Requirements: Companies providing cryptocurrency asset services must register as cryptocurrency asset service providers (VASP) and meet capital, reserve, and information disclosure requirements.

• Special regulations for stablecoins: Establish reserve asset, capital requirements, and daily liquidity limits for stablecoin issuers, particularly restricting the usage scale of non-euro stablecoins in the eurozone.

II. Implementation by Member States and Market Response

1. The implementation of MiCA adopts a "dual-track" transition period:

• Crypto service providers operating in the EU have a transition period of 12-18 months to adapt to the new regulations.

• Newly-entering market enterprises must immediately comply with MiCA regulations.

2. The market reaction shows polarization:

• Compliant enterprises welcome the legal certainty brought by unified standards, making it easier to operate freely in the markets of the 27 member countries.

• Innovative enterprises are concerned that strict compliance requirements may hinder flexibility, especially for DeFi projects.

1. Regulatory Agencies and Legal Framework

The Web3 regulation in Singapore is led by the Monetary Authority of Singapore (MAS), adopting a balanced model of "risk-based classification" and "sandbox testing:"

• Core Regulations: Mainly based on the Payment Services Act (PSA) and the Securities and Futures Act (SFA) to classify and regulate digital payment tokens (DPT) and security tokens.

• Regulatory Authority: MAS is responsible for licensing and overall supervision, while the Accounting and Corporate Regulatory Authority ( ACRA ) is responsible for corporate registration compliance.

2. Licensing System and Compliance Requirements

Singapore implements a classified licensing management for cryptocurrency businesses:

• DPT service license: Applicable to wallet services, exchanges, and custodians, requiring compliance with anti-money laundering ( AML ), capital safety, and minimum capital requirements.

• Capital Market Service License: Strict regulation applicable to security token issuance and trading under SFA.

MAS has set a moderately lenient exemption period for startups, allowing them to conduct limited business before fully meeting the requirements. This progressive regulatory approach has attracted well-known companies such as Circle and Paxos to settle.

III. Regulatory Dynamics and Market Impact

1. In 2024-2025, there is a trend of tightening regulation in Singapore:

• Stablecoin Regulation: The 2023 Stablecoin Regulatory Framework requires issuers to meet requirements such as 1:1 pegging of reserves, independent audits, and daily liquidity.

• New DTSP Regulation: In May 2025, MAS will release stricter regulatory guidelines for digital token service providers (DTSP), which will take effect on June 30, 2025, with no transition period, requiring unlicensed services to cease immediately.

2. Despite tightening regulations, Singapore remains one of the most attractive Web3 hubs in Asia, with advantages such as:

• The legal framework is clear and predictable

• Regulatory agencies maintain constructive dialogue with the industry

• Superior geographical location, radiating to the ASEAN market

Hong Kong******

Transformation from "Gray Area" to Compliance Testbed

The Financial Secretary of the Hong Kong SAR Government, Paul Chan Mo-po, has made important remarks on Web3 on multiple occasions, reflecting Hong Kong's proactive attitude and regulatory approach in promoting the development of Web3.

On April 7, 2025, at the "2025 Hong Kong Web3 Carnival" event, Chan Mo-po stated that Hong Kong is committed to promoting the development of the third generation of the internet (Web3.0) and plans to maintain fair market competition while encouraging industry innovation through a balanced and supportive regulatory framework.

He pointed out that blockchain technology is demonstrating great potential, significantly improving transaction efficiency, reducing costs, and enhancing market transparency, while the development of Web3.0 based on blockchain technology is also accelerating. Hong Kong has always adhered to the principle of "same business, same risks, same regulation" and is committed to establishing a suitable framework for the development of Web3.0.

Mr Chan mentioned that Hong Kong was one of the first jurisdictions in the world to establish a clear licensing regime for virtual asset trading platforms (VATPs), and that the Hong Kong Securities and Futures Commission has so far issued 10 VATP licenses. In 2024, Hong Kong will be the first to approve virtual asset spot ETFs (ETFs), making Hong Kong the largest virtual asset ETF market in the Asia-Pacific region, bridging traditional finance and cryptocurrency innovation.

1. Evolution of Regulatory Framework

Hong Kong's Web3 regulation has undergone significant changes:

• Before 2022: A relatively loose "regulatory vacuum" period that attracted a large number of cryptocurrency companies to register.

• 2022-2023: Transitioned to the principle of "same business, same risks, same regulations" through the Virtual Asset Policy Declaration and VASP licensing system.

• From 2024 to present: Comprehensive implementation of the licensing system to establish global compliance standards.

II. Core Regulatory Measures

1. Hong Kong adopts a multi-agency collaborative regulatory model:

• SFC: Responsible for licensing and regulating security tokens for the virtual asset trading platform (VATP).

• HKMA: Regulating stablecoins and payment-related services.

2. Key regulatory requirements include:

• Licensing System: All VATPs must obtain the 1st ( Securities Trading ) and 7th ( Automated Trading Services ) licenses issued by the SFC.

• Asset Custody: Requires custody of client assets through a wholly-owned subsidiary, obtaining a TCSP license.

• Investor Protection: Currently, only professional investors are allowed to participate in securities token trading, and retail investor protection is achieved through access restrictions.

3. Market Development and Policy Support

1. Hong Kong enhances its competitiveness through multiple measures:

• In 2024, the approval of spot ETFs for virtual assets will make it the largest virtual asset ETF market in the Asia-Pacific region.

• 2025 Policy Declaration: Plans to expand the regulatory framework, possibly including clearer rules for stablecoins.

2. The advantages of Hong Kong are:

• Capital and talent advantages brought about by the status of an international financial center

• Potential connection opportunities with the mainland market

• Clear regulatory expectations and legal certainty

1. Differences in Regulatory Philosophy

II. Comparison of Regulatory Oversight in Specific Sectors

1. Stablecoin Regulation:

• United States: Possible relaxation of regulations, focusing on payment functions

• EU: Strict capital and reserve requirements, restricting non-euro stablecoins

• Singapore: 1:1 peg requirement, independent audits, and daily liquidity

• Hong Kong: 100% reserve funds held in trust by banks, licensing system to be implemented within the year

2. Security Tokens:

• United States: Strictly applies securities laws, requiring registration or exemption

• EU: ART tokens are subject to MiCA, while other security tokens follow securities law.

• Singapore: Subject to SFA, but with a small issuance exemption

• Hong Kong: Disclosure of asset ownership and smart contract risks is required.

3. Decentralized Applications:

• United States: High-pressure regulation, strict law enforcement

• EU: MiCA retains some exemptions

• Singapore: The sandbox mechanism supports experimentation

• Hong Kong: Regulatory framework not yet clarified, may fall under VASP category.

In the future, global regulatory coordination will become even more important with the development of emerging issues such as tokenized (RWA) of real-world assets and on-chain privacy. Regulators need to find a dynamic balance between protecting the financial system and maintaining technological viability, while industry players need to develop adaptive strategies in a complex and dynamic regulatory environment. The future of Web3 depends not only on technological innovation, but also on regulatory wisdom, and only by exploring viable models within the framework of rules can this revolutionary technology realize its transformative potential.