Noise, anxiety, and excitement intertwine.

Written by: Shao Jiadian, Partner Lawyer at Mankun (Shenzhen) Law Firm;

Xu Xiaohui, Lawyer at Shanghai Mankun Law Firm

On May 21, the moment the Hong Kong Legislative Council passed the currency regulation bill in its third reading, the barrage in the adjacent crypto trading group went completely crazy:

"The era of licensing has officially begun, small players have no chance!"

"Now rushing to issue stablecoins? If you’re not tough enough, don’t go for it!"

"PayFi is the real gold mine; if you don’t act now, the soup will be gone!"

Noise, anxiety, and excitement intertwine. But the true veterans of Web3 are unusually calm at this moment. They know that the passage of the regulation is not the end; it is precisely the moment when the new game rules are set to start. When those giant stablecoin issuers begin to line up to apply for their "Hong Kong ID," a grand drama of wealth reorganization around the stablecoin ecosystem has just begun.

Entrepreneurs, don’t just watch the giants fight; open your eyes and look at what’s beneath them—countless new tracks are cracking open, waiting for you to position yourself and mine for gold!

The "Stablecoin Licensing Game": Hell Mode Activated, the Beginner's Village is Closed!

Let’s get the ugly truth out of the way: If you are still thinking about "issuing a stablecoin in Hong Kong and becoming rich overnight," I advise you to dispel that thought as soon as possible. This track has already been locked down into a "premium player exclusive dungeon." What exactly makes it difficult? Let me count the ways:

(1) Sandbox Players: The "Chosen Ones" Who Got a Head Start Two Years Ago

The Hong Kong Monetary Authority's regulatory sandbox is like a "stablecoin preschool," which has already recruited a batch of "top students" for training two years ago, such as JD's stablecoin project and Yuan Coin's stablecoin project. These players have polished their system development, compliance processes, and risk control systems clearly in the sandbox. Once the regulation is in place, they directly graduate with a license, effectively leading newcomers by two laps. What can a small team just entering the field compete with? They have written tens of thousands of lines of code while you are still figuring out how to pass compliance checks; the gap is larger than that between a top student and a failing student.

(2) Devilish Clauses: Curing Various "Garage Startup" Fantasies

The "sufficient financial resources" requirement in the regulation is no joke. For example, if you want to issue a stablecoin in Hong Kong, the registered capital alone must be HKD 25 million, and you must prove the ability to generate continuous profits—this alone can eliminate 99% of grassroots entrepreneurs. Not to mention the requirement to "establish a local entity"; you need to rent an office in Hong Kong, hire a compliance team, and maintain technical staff, costing millions each year. This is not entrepreneurship; it’s clearly a "money-burning competition"! Think about the days when USDT could start in a garage; those days are long gone. Now, it’s a "financial aristocrat game," and if you don’t have some capital, don’t even think about it.

(3) Regulatory Scrutiny as Detailed as "Checking the Water Meter," One Misstep and You’re in Trouble

In the past, issuing stablecoins might have involved some "sneaky operations," like covering for insufficient reserves, but that’s no longer possible. The regulation requires that reserve assets must be 100% equivalent and can only be cash, short-term government bonds, and other highly liquid assets. Want to use stocks or real estate as collateral? No way! What’s worse, the custodian and the issuer must be strictly separated, and audits must be real-time and transparent—put simply, every penny must be laid out for regulators to scrutinize, and even the two decimal places cannot be wrong. If you don’t have a professional financial team and technical system, you could be caught with problems in no time; fines are the least of your worries, and you might even end up in court.

(4) Policy Risks Are More Exciting Than Speculating on Coins; Ordinary People Can’t Afford to Play

Stablecoins involve monetary sovereignty, so how could the Hong Kong government casually issue licenses? In the coming years, it will definitely be "pilot first, steady progress," with only a few licenses likely issued each year, making the competition as fierce as "thousands of troops crossing a single-log bridge." Moreover, policies can change at any time; what is allowed today might be tightened tomorrow. You, a small team, work hard for a year, only to find you didn’t get the license, and your money is all burned up—what’s the point?

Entrepreneur Wake-Up Call: Small and medium-sized enterprises and startup teams can basically give up hope; don’t fantasize about becoming stablecoin issuers in Hong Kong. This track is a gladiatorial arena prepared for giants who are not short of money, people, or political and business connections. But! Don’t be discouraged! The real gold, belonging to entrepreneurs, is hidden in the ecological niches outside the "license walls" built by the giants!

Ecological Niche Gold Mining Guide: Five Core Tracks, There’s Always One That Suits You

Since the path of issuing coins is blocked, let’s change our thinking: sell "shovels" to those who issue coins and "build roads" for those who use stablecoins. The Hong Kong regulation actually draws a very clear boundary: issuing coins requires a license, but all service scenarios around stablecoins are open. I’ve outlined five major compliance opportunities; there’s bound to be one that suits your taste.

(1) Core Track One: PayFi Infrastructure—Earn Money from "Stablecoin Circulation"

This is definitely the "main battlefield" for small and medium teams. Why? Because the regulation clearly states "encouraging the development of stablecoin payment and clearing systems," and the market demand is explosive. Simply put, the giants are responsible for issuing coins, and we are responsible for making the coins "flow," just like WeChat Pay and Alipay don’t issue currency but make a fortune from payment interfaces. How to play specifically?

1. Cross-Border Payments: Let Foreign Trade Bosses Say Goodbye to the Pain of "Waiting Three Days for Money"

How troublesome is traditional SWIFT transfer? A cross-border remittance takes three days to arrive, and the fees are outrageous, especially for small and medium foreign trade enterprises, where the exchange rate losses alone are enough to make one weep. But using stablecoins is different: USDC transfers arrive in three seconds, with fees less than 10% of traditional methods.

For example: Suppose there’s a cross-border e-commerce boss with a monthly turnover of several million USD. Using traditional methods, he spends over HKD 20,000 just on fees each month and often gets urged by suppliers due to slow arrivals. If you set up a stablecoin payment channel for him, he could save 80% on fees, and funds would arrive in real-time—wouldn’t he be happy?

2. Merchant Settlement: From Milk Tea Shops to Chain Brands, Everyone Needs "Instant Arrival"

Many merchants are already using USDT for payments, but they are doing it secretly. After the regulation is implemented, a compliant stablecoin payment system will be a necessity.

For example: Milk tea shops, tea restaurants, and chain retailers everywhere want to collect money faster and at lower costs, right? If you develop a payment platform/tool that allows them to settle USDC, FDUSD, and other stablecoins in real-time, with fees 80% lower than traditional POS machines or payment gateways, and funds arriving instantly, wouldn’t the bosses love you?

3. Multi-Chain Clearing: Be the "UnionPay of the Crypto World," Earning Passive Income from Traffic

One of the biggest pain points in the crypto world is "lack of interoperability between chains": USDC on ETH, USDT on Solana, DAI on Polygon… What should merchants do if they want to receive HKD? How can users make cross-chain payments? This is where a "multi-chain clearing hub" is needed, just like the interbank UnionPay system, to connect the liquidity of stablecoins across different public chains, allowing stablecoins to truly flow, with value being self-evident.

(2) Core Track Two: Compliance "Arms Dealer," Selling Tools to Licensed Giants

The stricter the regulations, the greater the demand for compliance services. Just like the rise of e-commerce platforms gave birth to a large number of operation and quality inspection service companies, the compliance needs of stablecoins will also create a trillion-dollar market. What specific opportunities are there?

1. Anti-Money Laundering Tools: Making On-Chain Transactions "Transparent"

Regulations require stablecoin issuers to monitor transactions in real-time, and once suspicious addresses (like those associated with exchange hackers) are detected, they must be reported immediately. This is where a "black and white list screening tool" is needed; for example, you could develop an API that connects to data from major public chains to help issuers automatically identify risky addresses. For instance: If a certain address suddenly receives 100,000 USDC and then disperses it to 100 new addresses, your system can automatically trigger an alert, indicating possible money laundering behavior. Such tools can charge annual fees, with one client paying between HKD 100,000 to 200,000; ten clients could sustain a small team.

2. Audit Services: Giving Stablecoins a "Check-Up"

Previously, USDC released a reserve report every month, which was well-received because users needed to know if their money was genuinely secure. Now, the Hong Kong regulation requires issuers to regularly disclose reserve information, which necessitates a professional audit team. You could establish a "stablecoin auditing firm" to help issuers perform real-time reserve verification, such as checking whether their bank account balances match the circulating amount of stablecoins and issuing transparent reports. This service commands high fees and requires professional qualifications; once you secure a few major clients, you can establish industry barriers.

3. Regulatory Technology (RegTech): Making Compliance "Automated"

Many small and medium issuers lack the capacity or necessity to develop compliance systems themselves. In this case, you could create a "compliance report generator," for example, integrating their financial data and on-chain transaction data to automatically generate reports that meet the Monetary Authority's requirements for one-click submission. Just like current tax software, simplifying complex compliance processes into "one-click operations," such tools can charge hundreds to thousands of HKD per month, and with a large client base, you can make significant profits.

(3) Core Track Three: Cross-Chain Bridging—Be the "Ferry Operator of the Stablecoin World"

The multi-chain universe is an unstoppable trend. Along with it comes an explosive demand for stablecoin cross-chain transactions, especially in:

• Enterprise payment scenarios: What if the stablecoin on the payer's chain doesn’t match the chain/currency needed by the payee?

• DeFi clearing and arbitrage: The interest rate differentials and liquidity differences of stablecoins across different chains present opportunities, but how to move them efficiently and cost-effectively?

When USDC is comfortably resting on Ethereum, USDT is frolicking on Tron, while the tea restaurant owner in Hong Kong only recognizes HKD… A safe, fast, and low-slippage stablecoin cross-chain bridge becomes an absolute necessity!

• Opportunity: Develop a secure, efficient, and low-slippage cross-chain protocol or service focused on stablecoins. Key support for mainstream public chains in the Hong Kong market: ETH, Solana, TON, Polygon, etc.

• Technical Lifeline: Security! Security! And more security! The recent incident where the Nomad bridge lost hundreds of millions overnight is still fresh in memory. Your bridge must be armed to the teeth: consider introducing advanced cryptographic technologies like zero-knowledge proofs (ZK) for security verification, and ensure multi-signature and decentralized oracle networks are all in place. Security is 1, and everything else is just zeros after it.

Avoid Legal Red Lines: When designing mechanisms, you must strictly guard against being classified by regulators as a disguised issuance of coins (for example, generating assets out of thin air through the bridge) or causing multi-chain inflation issues. This requires close collaboration between legal and technical teams.

(4) Core Track Four: Stablecoin Asset Management—Letting "Idle" Stablecoins "Give Birth"

If the stablecoins in users' hands are just sitting there, they yield no returns, but the Hong Kong stablecoin regulation does not allow issuers to directly offer interest. What to do? This is where asset management services are needed to help users make their stablecoins "earn money":

1. Accessing DeFi Protocols: Earning Interest Rate Differentials

You could create a platform that connects users' stablecoins to lending protocols like Compound and Aave, with the interest earned after deducting your service fee going to the users. For example, if the current borrowing rate for USDC on Compound is 4%, and you charge a 1% service fee, the user nets 3%, which is much higher than a bank's savings account. But remember: absolutely no promises of capital preservation! You must prominently display risk warnings on the page, such as a big title: "DeFi is risky; invest with caution," otherwise, if the market crashes and users incur losses, they might sue you.

2. Real Asset (RWA) Returns: Investing in Government Bonds and Real Estate

In addition to DeFi, stablecoins can also be directed towards real-world assets, such as tokenized U.S. government bonds. Users can purchase "bond tokens" with USDC and receive interest periodically, while you collect management fees from this model. This approach is more compliant since government bonds are low-risk assets with high regulatory acceptance. There are many asset management companies in Hong Kong that excel in RWA; you can collaborate with them for front-end sales and compliance integration.

Teams like Circle (through its asset management branch), Maple Finance (focusing on institutional lending), and Ondo Finance (RWA pioneer) are already exploring this path. With its mature financial market and open regulatory attitude, Hong Kong is fully equipped to make this model compliant and scalable. This is suitable for teams proficient in financial engineering, familiar with structured products, and capable of navigating compliance frameworks.

(5) Core Track Five: Reserve Asset Management—Be the "Steward of Stablecoins"

Stablecoin issuers looking to obtain or renew licenses must have top-notch custody, management, and risk control arrangements for their reserve assets (cash, short-term government bonds, and possibly a small amount of high-rated RWA). This means:

• A surge in demand for professional asset custodians (requiring appropriate licenses).
• Audit firms need to provide more granular services.
• Asset valuation firms need to offer real-time or high-frequency pricing.
• There may even be a need for professional teams to provide government bond allocation strategies and foreign exchange hedging solutions (which also require licenses or strong qualifications).

Core Logic: Don’t try to build the giant ship (issuing coins); instead, be the essential "ballast" and "escort ship" for the giant ship! Hong Kong has Asia's top financial custody, clearing, and asset management ecosystem, which is a natural home-field advantage for local professional service providers.

The table is set; which chair will you choose?

The implementation of the Hong Kong stablecoin regulation is by no means the final chapter of the story. It is more like a clear and powerful shot that signals the start of the global stablecoin regulatory race, with Hong Kong taking the lead. While lawmakers in New York are still debating and Singapore's framework is still being patched up, Hong Kong has already unveiled clear, predictable rules that align with international standards—this itself is a significant and rare institutional dividend!

Stop fixating on the "issuing coins" pinnacle; look at the ecological niches around you: some earn tens of millions annually by creating payment interfaces, some are valued at over a hundred million by selling compliance tools, and some secure top-tier institutional investments through cross-chain bridges. The game of stablecoins in Hong Kong has already begun; the giants are issuing coins, and we ordinary people can be the ones "selling tea and renting chairs beside the dealer," still finding our place in this new financial era.

Finally, let me leave you with a thought: In the world of Web3, smart entrepreneurs never confront giants head-on; instead, they dig their own gold mines in corners where the giants cannot see. In this new era of Web3 where licenses reign supreme, compliance is no longer just a baseline; it is your sharpest and most indispensable ticket to entry! Recognize the track, position yourself accurately in the ecosystem, and you can strike gold in this wave of stablecoins led by Hong Kong.

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