A US-dollar-anchored stablecoin trying to operate at retail scale across the European Union, Hong Kong, and mainland China runs into three legally dissimilar instruments: a transaction cap, a professional-investor gate, and an outright prohibition. Two of the three constraints bind through published text and the third operates partly through unpublished signal on the cross-border pathway. The shared policy object is distinct from the prudential, consumer-protection, and law-enforcement concerns that occupy the rest of these regimes. A single dollar-anchored stablecoin cannot serve these three jurisdictions at scale as a retail payments rail on uniform terms, which reflects regulatory geography and is not about market preference or technology.
Three constraints, three mechanisms
European Union
Article 58 of the Markets in Crypto-Assets Regulation (Regulation (EU) 2023/1114, “MiCA”) establishes a cap-and-cease regime for e-money tokens denominated in a currency that is not an official currency of a Member State and used as a means of exchange: one million transactions per day or €200 million in daily transaction value, both measured as quarterly averages within a single currency area. Article 23 imposes a parallel cap on asset-referenced tokens used as a means of exchange within a single currency area, capturing basket-pegged structures by a different statutory route. Above the threshold the issuer must stop issuing and submit a usage-reduction plan within forty working days. The cap reaches only use as a means of exchange. Store-of-value holdings and trading flows through crypto-asset venues are explicitly carved out. The carve-out is the regime’s most telling feature: the porousness on the side that does not threaten the euro confirms the policy object is currency substitution in transactions, not dollar-denominated assets generally. The European Banking Authority’s No-Action Letter of 10 June 2025 on the interplay between the second Payment Services Directive (PSD2) and MiCA adds a second operational layer: from 2 March 2026, custody and transfer of e-money tokens by crypto-asset service providers require both MiCA authorization and a payment institution or electronic money institution authorization under PSD2.
Hong Kong
Foreign-based issuers of fiat-referenced stablecoins not pegged to the Hong Kong dollar (HKD) may offer their tokens to Hong Kong professional investors only (Stablecoins Ordinance (Cap. 656), in force 1 August 2025). Retail distribution requires HKD anchoring or local licensing by the Hong Kong Monetary Authority (HKMA). On 10 April 2026, the HKMA granted the first two issuer licenses: HSBC Hong Kong (FRS02) and Anchorpoint Financial Limited (FRS01), the latter a joint venture of Standard Chartered Bank (Hong Kong), HKT, and Animoca Brands. Both licensees are HKD-anchored. The applicant funnel moved from seventy-seven expressions of interest at the end of August 2025 to thirty-six formal applications by 30 September, and two licenses on 10 April.
Mainland China
The People’s Bank of China’s (PBOC) 2017 initial-coin-offering Notice and 2021 framework on virtual currency trading speculation prohibit all non-renminbi tokens domestically. In October 2025 the PBOC and the Cyberspace Administration of China issued private directives – reported but not published – instructing subsidiaries of Ant Group and JD.com to pause their Hong Kong stablecoin plans (Financial Times, 19 October 2025; Reuters wire). The HKMA, asked to comment, declined. Six months later the HKMA’s first-cohort licenses went to HSBC and the Standard Chartered–led Anchorpoint Financial; no PRC-connected applicant appeared. The privately held internet groups that had paused in October were not in the cohort; neither were the state-owned commercial bank affiliates whose September 2025 application activity had been publicly reported (Bank of China (Hong Kong), ICBC (Asia), Bank of Communications (Hong Kong), and China Construction Bank (Asia)). The codification asymmetry matters for the analysis that follows: MiCA and Cap. 656 bind durably and transparently through published text; the PRC limb rests partly on signal rather than rule.
United States, Singapore, United Kingdom
The GENIUS Act (Pub. L. No. 119-27) imposes no non-USD cap. The Monetary Authority of Singapore’s Single-Currency Stablecoin framework (August 2023) accepts the Singapore dollar or any G10-pegged token. The Bank of England’s November 2025 proposals on sterling-denominated systemic stablecoins impose prudential constraints — reserve composition, holding limits — on a different axis: monetary stability for systemic stablecoins denominated in the home currency, not cross-currency substitution. Domestic-currency prudential rules and non-domestic-currency sovereignty caps are different instruments addressing different policy objects.
What the three caps protect
For the eurozone, large-scale dollar e-money token flows in transaction settlement would erode the euro’s role and complicate European Central Bank monetary-policy transmission. For Hong Kong, the HKD–USD peg is the foundation of HKMA monetary policy, and uncontrolled circulation of dollar-anchored retail stablecoins would direct settlement demand toward the dollar, not toward the pegged HKD that the peg arrangement is designed to sustain. In both cases, what the caps protect is sovereign authority over which currencies dominate domestic payments infrastructure, something the prudential, consumer-protection, and law-enforcement layers of these regimes do not address.
For mainland China, the digital yuan programme is a PBOC strategic priority. A source described the regulatory concern to the as a question of who holds “the ultimate right of coinage” — the central bank or private issuers — a framing that places the central bank itself on one side and commercial issuers, whether private or state-owned, on the other. The first-cohort composition is consistent with this reading. The HKMA’s two licenses went to HSBC and a Standard Chartered–led joint venture, covering two of Hong Kong’s three HKD note-issuing banks. The third — Bank of China (Hong Kong), or BOCHK — would have been the natural pick under a pure incumbent-capture criterion. It was not in the cohort. Neither were Ant, JD, ICBC (Asia), Bank of Communications (Hong Kong), or China Construction Bank (Asia). The joint exclusion of state-owned and privately held PRC-connected applicants alike cuts against incumbent capture. Under the coinage-prerogative axis the FT source articulates — sovereign monetary authority on one side, commercial issuance on the other regardless of public or private ownership — the data are coherent. The single-cohort record cannot definitively distinguish this from a pure PRC/non-PRC nationality criterion; the actors themselves, however, describe their concern in coinage terms, not in nationality terms.
Singapore imposes no cap because the Singapore dollar is not under dominant-currency pressure. The United States imposes none either, but for the opposite reason: the dollar is itself the currency the three other caps defend against, so the question of constraining its expansion does not arise from a U.S. monetary-sovereignty perspective. The configuration places the United States as the residual beneficiary of the asymmetry. The GENIUS Act imposes no symmetric cap on non-USD tokens within the United States, leaving the asymmetry undisturbed; through §18, foreign payment stablecoin issuers may enter the U.S. market only on a Treasury “comparability” determination, which projects the U.S. framework outward as the reference standard against which other regimes are measured. The cap-and-cease, the professional-investor gate, and the prohibition are foreign-jurisdiction responses to what is, on the American side, a policy choice not to constrain dollar expansion through stablecoin rails.
One caveat on the PRC limb. The case is over-determined: the domestic prohibition reaches most private crypto-asset activity, not only non-renminbi stablecoins, so monetary sovereignty is one driver among several. The point holds cleanly for the European Union and Hong Kong; for the PRC, multiple drivers overlap, and the operative instrument on the cross-border pathway is partly signal rather than rule.
The architecture that follows
For firms operating across currency areas, these constraints are permanent features of the regulatory landscape, not transition-period frictions. Article 58’s transaction cap, Hong Kong’s professional-investor threshold, and mainland China’s prohibition bind through different mechanisms but produce the same effect: each currency area’s regulated retail rail anchors to its own currency token, and cross-currency settlement migrates to licensed foreign-exchange rails or trading venues, not to a unified single-currency token. The dollar’s structural advantages preserve substantial cross-border activity in treasury holdings, trading flows, and professional-tier settlement; the retail payments rail cleaves along currency-area boundaries. The same regulatory landscape produces sovereignty caps, domestic-currency prudential rules, and no caps at all, in parallel rather than in sequence.
The closest existing comparative analysis on the cross-jurisdictional axis is Benedikt Bartylla, How the GENIUS Act Regulates Foreign Issuers—and How It Compares to Europe and the UK (Yale Journal on Regulation, Notice & Comment, 25 August 2025), which addresses §18 and the GENIUS Act’s foreign-issuer architecture in a US/EU/UK frame. The present piece extends that frame to six jurisdictions, adding Singapore, Hong Kong, and the People’s Republic of China — the three jurisdictions on which the asymmetry runs most starkly against dollar-dominated retail rails.
Conditional regulatory status
Three developments, each unresolved as of May 2026, would modify the analysis. First, Member State competent-authority enforcement practice under the EBA’s Article 58(3) measurement methodology (EBA/RTS/2024/13, June 2024) is not yet observable in published form. Second, the HKMA has not announced the composition of its second cohort of fiat-referenced stablecoin licenses; the next public data point on PRC-connected applicants will come from that announcement. Third, the People’s Bank of China and the State Administration of Foreign Exchange have not made any public policy statement that either reaffirms or modifies the cross-border boundary observed in October 2025 and April 2026. The architectural implications described above should be read against the boundary as currently observed; modification of any of these three would require corresponding re-derivation.
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Yunjie Fan is an independent researcher working on cross-jurisdictional stablecoin regulation. The framework developed here is set out at greater length in Cross-Border Stablecoin Architecture: A Constraint-Based Analytical Framework (SSRN, May 2026). Related portfolio work includes Narrowing the Section 404 Prohibition (SSRN, May 2026), filed with the SEC Crypto Task Force on 7 May 2026.
Methodology Note. The author has received no compensation — direct, contingent, or otherwise — for this piece, the underlying research, or any companion work in this portfolio, and is not currently engaged in advisory, consulting, employment, or other compensated relationships with any party having a financial interest in the regulatory outcomes discussed. The analysis draws exclusively on public sources: enacted statutes, published or proposed regulations, agency releases and supervisory publications, central bank publications, public corporate disclosures, and published academic and practitioner literature.
