Author: Wu Talks Blockchain

In this episode of the podcast, we invite the well-known analyst Zheng Di, who is highly regarded and loved. He has worked for several mainstream securities firms and has been actively involved in the development of the Web3 industry in the Greater China region.

In recent years, Hong Kong has shown strong development momentum in terms of policy inclusiveness and industrial layout, attracting more and more crypto practitioners. Especially against the backdrop of tightening regulations in Singapore, some centralized exchanges and practitioners with Chinese backgrounds that failed to obtain licenses or faced other restrictions have begun to turn their attention to Hong Kong.

At the same time, many people are skeptical about Hong Kong's development, believing it does not have the conditions to become a Web3 hub. Particularly in the context of frequent policy fluctuations in mainland China, the topics of stablecoins and RWA (Real World Asset tokenization) in Hong Kong have sparked widespread attention.

Zheng Di is currently based in Singapore but frequently travels between Hong Kong and Singapore, making him very familiar with the policy environment and market dynamics of both places. In this episode, he will analyze in detail the similarities and differences in Web3 regulatory directions between Hong Kong and Singapore, discuss whether Hong Kong can stand out and become the global center of the next generation of the crypto industry, and delve into the trends in the stablecoin market, the regulatory prospects for stock tokenization, and the significant differences in RWA development paths between China and the United States.

For the complete audio, please search for Wu Talks on mainstream audio platforms like Xiaoyuzhou. This article does not constitute any investment advice, and the author's views do not represent Wu Talks. Readers are advised to strictly comply with the laws and regulations of their location.

Comparison of Regulatory Attitudes between Hong Kong and Singapore: The Battle for Web3 Hub

Colin: First, please share why you believe Hong Kong will become the next Web3 hub. Is it a center for the Asia-Pacific region or a global center?

Zheng Di: Thank you, Colin. Hello everyone, it’s a great honor to discuss this topic with you again today.

In fact, I believe Singapore is under pressure in terms of regulation, especially influenced by the FATF (Financial Action Task Force), which requires its member countries to regulate all virtual asset service providers (VASP) registered in their countries, even if these services are not provided within their borders. Therefore, Singapore's recent regulatory actions, including the implementation of the DTSP license, are responses to this international regulatory pressure.

As early as 2022, Singapore announced this policy. However, many practitioners in Singapore were unaware at the time or thought there might be a grace period, or felt that obtaining a license would not be difficult. Thus, they were quite surprised by the complete enforcement of the "regulatory cliff" on June 30, 2025—there was no transition period, and it was a direct cut-off, resulting in many practitioners being forced to leave.

It was not surprising that some small exchanges left, but what shocked me was that even licensed platforms in Hong Kong, which are well-known in Singapore, had to exit because they could not obtain a Singapore license. This indicates that Singapore is indeed reluctant to continue accommodating these institutions.

This does not mean that Hong Kong is free from regulatory pressure; Hong Kong is also a FATF member and will be evaluated. However, because Singapore's evaluation came first, the pressure became apparent earlier. If Singapore fails to clean up relevant platforms in this evaluation, it may be placed on the "grey list" or even the "black list," which would greatly affect its status as an international financial center and capital flow.

In contrast, Hong Kong has fewer options. In recent years, many outbound institutions, including Chinese-funded enterprises, have chosen Singapore, not limited to Web3 financial companies. For Singapore, even if it loses Web3, it still has other sectors like AI to support it, so it has no strong motivation to embrace Web3.

But Hong Kong is different. A few years ago, it was even referred to as an "international financial wasteland," so it urgently needs to find a new direction for development. Web3 has become a breakthrough point chosen by policy. Moreover, Singapore's sovereign fund had previously suffered significant losses in the Web3 and NFT sectors, which has led the government to have a negative perception of this industry.

Singapore has publicly stated that it will not issue too many DTSP licenses, and there are considerations regarding the industry's contribution: the Web3 industry has not provided sufficient local employment and tax revenue, and many people use stablecoins for salaries, resulting in very little tax being paid; there are also complaints from citizens about Web3 personnel driving up the cost of living. Additionally, 2025 is an election year, and the government's increased regulation may also be a response to public opinion.

Therefore, Singapore has chosen to "drive away" part of the industry by controlling the number of licenses. In contrast, Hong Kong, facing similar regulatory pressures but with fewer alternative industries, has opted for a relatively flexible approach, such as providing transition periods and clear licensing guidelines.

In summary, both places face the same external regulatory pressures, but due to differences in industrial structure and options, Hong Kong and Singapore have very different attitudes towards Web3. This reflects the strategic positioning differences of both places regarding the Web3 industry.

The Evolution of Hong Kong's Position: The Possibility of Transitioning from a Greater China Center to a Global Web3 Hub

Colin: I think Zheng Di has made the background of Singapore very clear, helping everyone understand why Singapore currently shows a trend of "kicking people out." Now, regarding Hong Kong, can we continue to discuss whether you think Hong Kong is more of a Web3 center for Greater China or if it has the potential to become an Asia-Pacific center or even a global center?

Zheng Di: In fact, if it weren't for some recent changes since April this year, I would have thought that Hong Kong was just a Web3 center for Greater China, mainly relying on support from the mainland. The development of Web3 in Hong Kong has largely been driven by some industrial policies from the local government. Therefore, many people in the market have held a mocking attitude towards those projects and practitioners that moved to Hong Kong or Cyberport.

However, we cannot ignore a question: will China's policy attitude remain unchanged forever? In the Web3 industry, I personally feel that there is a sense of "shame" among Chinese practitioners, especially those of Asian descent—because the industry is not encouraged in China, and only Hong Kong provides a marginal space for them, lacking clear and positive regulatory guidance.

At the same time, the United States is actively leading the formulation of rules for this industry. Since Trump's election, the U.S. has continuously introduced crypto-friendly regulatory frameworks. For example, the recently passed GENIUS Act in the House of Representatives, although the Senate version has not yet been released and there is no mandatory long-arm jurisdiction, has already made it clear: if foreign stablecoin issuers do not comply with its rules, they will be excluded from the U.S.-led crypto financial system.

Therefore, many jurisdictions, including Hong Kong, may be seeking to align with the U.S. regulatory framework to achieve "mutual recognition," allowing compliant stablecoin issuers to smoothly enter the U.S. market. This reliance on U.S. standards makes it difficult for Hong Kong to shake off its identity as a "guest player" even while striving to develop Web3.

However, we have recently observed a shift in policy direction. Notably, the CNH stablecoin launched in collaboration with Conflux and the Hongyi Group made it to the front page of the Liberation Daily, which is a very special signal. Additionally, the Shanghai State-owned Assets Supervision and Administration Commission and the Wuxi government are also studying stablecoins, and the public statements made at the Lujiazui Forum on June 18 also conveyed positive information.

These developments indicate that mainland China's policies are undergoing subtle adjustments. Therefore, Hong Kong's positioning is no longer limited to being a Greater China center but is more likely to become a Web3 center for all of Asia. Even if we do not consider the mainland market, Hong Kong already has a certain foundation based solely on the application scenarios of Chinese enterprises and banks overseas.

From a global perspective, although China has fiercely competed with the U.S. in trade, tariffs, and technology, it has never mastered the pricing power of financial assets. This is because Western financial rules are still dominated by the U.S., and most countries globally follow its regulatory system.

Now, we are at an unprecedented juncture in the reconstruction of the financial system. The originally tightly-knit SWIFT system is being upgraded, and the U.S. hopes to lead this upgrade and quickly fill the "gaps" during the process, continuing to consolidate its dominance in the on-chain financial system.

The latest provisions of the GENIUS Act clearly reflect this intention, but it also provides China with a rare historical opportunity. If China can seize this window where on-chain financial infrastructure has not yet fully closed and gain a certain degree of discourse power, it can not only participate in building a new system but also potentially challenge the existing financial hegemony.

On-chain finance is not something that any single country or government can build alone; it is the result of years of joint efforts by global users, project parties, and investors. The U.S. is adept at formulating rules to achieve indirect control, and if China can join the rule-making process, it is likely to counterbalance this.

If China introduces friendlier policies at this stage to promote local enterprises' participation in on-chain finance, especially in key areas like stablecoins, RWA (Real World Asset on-chain), and STO (Security Token Offering), then not only is Hong Kong likely to become an Asian center, but it may also stand alongside New York as a new global Web3 center.

From the perspective of offshore finance, the Global South, which includes 30 to 50 countries with foreign exchange controls or significant currency fluctuations, represents the most practical application scenarios for on-chain finance. If China can seize this market, it will have a significant advantage in on-chain stablecoins and asset trading.

Therefore, I believe that now is a critical decision-making window for China's policies. If seized, China is expected to shape the on-chain financial landscape alongside the U.S. in the next three to five years; conversely, this window may close rapidly.

In conclusion, I believe Hong Kong has at least become the Asian Web3 center and is moving towards becoming a global hub. Whether this goal can be achieved ultimately depends on whether the Chinese government can make the right strategic choices at critical moments.

The Battle for Stablecoin Licenses in Hong Kong: The Game of USDT Hegemony and Regulatory Window

Colin: There are also some concerning issues in Hong Kong, such as the "Global South" you just mentioned, where the use of USDT has become very widespread in third-world countries. If Hong Kong wants to reintroduce a stablecoin, especially one pegged to the RMB or HKD, it would be directly competing with USDT. Isn't that too difficult? Moreover, the attitude of mainland China, especially Beijing, towards this matter is also unclear, and past policy fluctuations make it hard to judge whether this can truly rise to the national level.

Zheng Di: I actually agreed with this view before I saw the U.S. House of Representatives pass the GENIUS Act. Indeed, USDT is like a "behemoth," almost invincible in offshore scenarios. However, after the House version of the GENIUS Act passed, especially after Trump's signature, USDT was also forced into a compliance process. It has a three-year transition period, and according to Tether's CEO, Tether will issue a fully compliant stablecoin registered in the U.S., primarily serving institutional-level, high-speed, transparent payment scenarios. Meanwhile, USDT will be treated as a "foreign issuer," hoping to still smoothly enter the U.S. and the entire Western crypto financial system.

However, in this process, USDT must also make adjustments, such as changing its reserve structure to meet the requirements of the GENIUS Act. This means its excess profits will no longer exist. Although USDT will still strive to make money during these three years, it must be fully compliant after three years, establishing a blacklist mechanism, KYC system, and anti-money laundering measures.

It is precisely this three-year compliance window that has created new market space, allowing offshore stablecoins to have development opportunities. The future stablecoin competition market will become more intense.

If I were Jeremy from Circle (co-founder and CEO of Circle), I would actually prefer that Tether not be overly pressured to comply. This is because the two are currently in different markets: USDT primarily targets the Global South, while Circle focuses more on the U.S. domestic and institutional scenes. If USDT becomes compliant, it would shift from the offshore market to the U.S. market, becoming a direct competitor to Circle. Such a change would disrupt the existing market structure.

Once USDT is pulled into the compliance system, it will leave a gap in the original offshore market, providing space for other stablecoins to rise, such as DAI and Ethena. These stablecoins, which originally ranked third and fourth, could seize the opportunity to grow.

I saw an interesting piece of news yesterday: previously, Coinbase's customer service was hacked, leading to the theft of $300-400 million in assets, which the hacker converted entirely into DAI, and these assets could not be frozen. Everyone was asking if they could be frozen. If it were USDT or USDC, it could be frozen, but DAI cannot be frozen. This also illustrates that decentralized stablecoins still have "gaps" in the offshore market.

Of course, these algorithmic or crypto-collateralized stablecoins (like Ethena and DAI), since they are not fiat-collateralized, will not be recognized by the GENIUS Act, and thus may be completely excluded from the future Western crypto financial system. Nevertheless, the gaps left during USDT's compliance process still provide opportunities for other players to grow.

Does this give local new players in Hong Kong, like the CNH stablecoin, an opportunity? It's hard to say, but it is certain that this is indeed a potential window for emerging players.

However, Hong Kong also faces very real challenges: on one hand, mainland policies are indeed loosening, and many people want to take the opportunity to strengthen Hong Kong's Web3 industry; but at the same time, there is a very strong conservative force, watching closely and ready to pick at Hong Kong's vulnerabilities. If any issues arise, it will be targeted.

Therefore, the Monetary Authority is currently behaving very cautiously. This caution comes from both internal pressures and the requirements of international regulation from the FATF. To maintain its status as an international financial center, it must align with the Western regulatory system, ensuring KYC and anti-money laundering measures are in place.

Singapore has chosen to fully comply, even at the cost of "destroying" its local Web3 industry. Although they claim to be "just cleaning up the non-compliant," the result is a significant tightening.

I think Singapore is somewhat like the Zhangjiang Hi-Tech Park in Shanghai—too trusting of large multinational companies while neglecting local small and medium-sized innovative forces. Zhangjiang lost the opportunity to become China's innovation drug center because it overlooked the innovative talent returning from overseas.

Similarly, Hong Kong does not have many options; it must preserve the Web3 industry while also dealing with regulatory pressure from the FATF.

Currently, Hong Kong is clearly "cooling down" the public discourse around stablecoins and is no longer easily issuing application forms. The Monetary Authority is now using an "invitation system"—only institutions they invite can apply for stablecoin licenses.

At the same time, the future of stablecoins may not follow the model of USDT or USDC, which allows for arbitrary transfers on public chains, but rather adopt a more cautious whitelist system, possibly similar to TMMF (Tokenized Money Market Fund), using on-chain deposit whitelist transfers.

All of this will depend on how policies are specifically implemented after August. But my overall feeling is that the Monetary Authority is more cautious than before. Hong Kong is facing a regulatory balancing act under dual pressures, not just internal but also external.

How Hong Kong Responds to Offshore Crypto Services: Finding Balance Between Regulation and Industry

Colin: Singapore has taken a rather unique approach this time. If you are registered in Singapore but do not serve local users and instead target offshore users, Singapore now holds a relatively exclusionary attitude towards this. In contrast, Hong Kong seems to be relatively more tolerant in this regard. For the crypto space, this issue is crucial, as it involves not only offshore centralized exchanges but also some decentralized products and even more other businesses. Singapore has denied this model, so do you think Hong Kong might also tighten in this area in the future? Currently, my understanding is that Hong Kong is still relatively tolerant or permissive.

Zheng Di: Yes, I think the key issue lies in the FATF's regulatory review. Singapore faced this pressure earlier than Hong Kong, and Hong Kong will certainly encounter it as well. However, from the current attitude, it is clear that Hong Kong wants to preserve its Web3 industry, which is a significant difference from Singapore.

Singapore's regulatory strategy relies heavily on large companies, so you will see that their licenses are mainly issued to large exchanges and major market makers, while smaller projects may be directly dismissed. But Hong Kong is different; it places more importance on small and medium-sized enterprises and understands that innovation often comes from these smaller institutions. The logic is similar in the U.S. Singapore has many options; it does not need to rely on these small and medium-sized Web3 startups, as it can simply follow the trend. Due to the current wave of outbound investment, many Chinese companies are choosing Singapore as their first stop, making Singapore naturally more "selective."

However, I still believe that Web3 is a very important industry. As a seasoned partner in a dollar fund told me, in the future, we only need to focus on two industries: AI and Web3, as these two have the longest slope and thickest snow; other industries do not warrant too much effort.

Therefore, I also believe that the Singapore government may reflect on its current choices in a few years. After all, the pressure from the FATF is global, and Hong Kong will not remain lenient forever. But the government's attitude still has operational space, such as whether to set a grace period or avoid creating a "regulatory cliff," which are all crucial.

For example, regarding the issuance of licenses—are you encouraging others to apply? Or are you setting up numerous obstacles, not wanting them to apply at all? The accessibility and transparency of the entire process determine a region's attitude.

Currently, Hong Kong has not significantly cracked down on offshore exchanges, DEXs, etc., nor has it prohibited them from serving users outside of Hong Kong. Whether there will be regulatory upgrades in the future is a possibility. But the key difference for Hong Kong is that it may encourage these institutions to apply for licenses, or even proactively extend invitations, rather than being "unwelcoming" like Singapore, which clearly states "we won't issue you a license."

For Singapore, after issuing licenses to a few large exchanges, major market makers, and stablecoins, it feels that it has done enough and no longer considers this industry a core pillar. But for Hong Kong, it does not have many options; Web3 may be its only strategic industry that can change the future.

Thus, while both places face FATF pressure, they have adopted completely different response strategies.

Of course, that said, Hong Kong's regulation is also tightening significantly. Previously, we saw many street-side exchange shops in Hong Kong, most of which operated OTC businesses with customs MSO licenses and trust licenses issued by the company registry.

However, now the Hong Kong Securities and Futures Commission (SFC) has launched the VA OTC license and opened public consultation, which will end at the end of August. Based on the current draft, it can be anticipated that if this VA OTC license is implemented according to the current standards, the vast majority of exchange shops in Hong Kong may be forced to close.

This will greatly block the anti-money laundering loopholes in the OTC channels—this has been one of the biggest regulatory blind spots in Hong Kong's Web3 ecosystem.

The new regulations require that even if you are a street-side exchange shop, whether chain or individual, you must have two Responsible Officers (ROs) with cryptocurrency experience, and such talent is very scarce, let alone having two. You must also meet a minimum registered capital of HKD 5 million, with cash not less than HKD 3 million, and it must cover the operating costs for the next 12 months. If expenses exceed HKD 5 million, you must also set aside additional reserve funds.

Such high thresholds are clearly not something ordinary small businesses can bear, so many small OTC points may exit the market.

It is evident that not only is Singapore raising regulatory thresholds, but Hong Kong is also gradually tightening, albeit through different paths—one is a direct cleanup, while the other is raising thresholds to guide compliance.

In summary, while both places are responding to the same international regulatory pressures, their attitudes and strategies are completely different. Hong Kong is still trying to find a balance between regulation and industry.

The Global Trend of Stock Tokenization: Regulatory Challenges and Hong Kong's Institutional Dilemma

Colin: Next, let's talk about another topic you might be paying attention to, which is the recent hot topic of RWA (Real World Assets) and stock tokenization. In the U.S., this direction is currently very hot, with many startups emerging, such as the collaboration between Kraken and xStocks, especially Robinhood's entry into the Pre-IPO stock tokenization market, which has garnered significant attention. Stock tokenization is also one of your areas of expertise. However, it seems that Hong Kong is facing some institutional issues. A few days ago, we interviewed legislator Mr. Qiu (Hong Kong Legislative Council member Qiu Dagen), and we also saw that Xiao Feng (Chairman and CEO of HashKey Group) is very concerned about this topic and actively participating in discussions. They believe that due to some old regulations after the stock market crash, Hong Kong stocks can only be traded on the Hong Kong Stock Exchange, completely sealing off the development path for stock tokenization. What do you think about Hong Kong's prospects in RWA and stock tokenization?

Zheng Di: Yes, currently there are mainly three paths for stock tokenization in the market: Robinhood, Gemini in collaboration with Dinari, and Kraken in collaboration with xStocks.

Among them, Robinhood's approach is completely compliant and without flaws. However, what it launched in the first phase is not a true stock token but a centralized CFD (Contract for Difference), operating under its MiFID license registered in Lithuania. This CFD is traded on-exchange and cannot be transferred on-chain.

In contrast, the stock tokens provided by Dinari and Kraken can be transferred on-chain 1:1. The essence of Robinhood's product is air; it does not have actual mapping to stocks. Although they do hold these stocks in the U.S., these underlying stocks are not collateral for the CFDs, so they do not constitute a 1:1 mapping and are not subject to strict regulation. This structure allows Robinhood to claim, "I am the buyer's counterparty," holding the underlying stocks merely as a hedging tool, not backing the CFDs, thus facing relatively less regulatory pressure.

However, the situations for Dinari and Kraken are more complex. They have done KYC on their on-exchange platform, which is fine, but once users transfer the tokens on-chain, they cannot guarantee that U.S. users won't purchase them, thus circumventing SEC regulation and taxation. Although they technically block U.S. users, the on-chain system is open, making it impossible to completely prevent abuse. This is a compliance loophole currently present in the structure.

Additionally, SEC Commissioner Hester Peirce, known as "Crypto Mom," has previously made it clear that even if only the rights to profits are tokenized and do not have voting rights, it still qualifies as a security. If one wants to provide securities trading to retail investors, it must be done on a licensed securities exchange, such as NASDAQ or the New York Stock Exchange; Coinbase cannot do it.

If one wants to provide such trading on-chain, it can only be offered to accredited investors. This is very similar to the situation in Hong Kong—after the stock market crash, the established system only allows the Hong Kong Stock Exchange to monopolize the trading rights of Hong Kong stocks, regardless of whether it is on-chain or not, stock trading can only occur on the Hong Kong Stock Exchange. This essentially closes off the potential paths for Hong Kong to promote stock tokenization.

However, there was new news a few days ago: SEC Chairman Paul Atkins is considering whether to grant some form of exemption for stock tokens to be traded on-chain. If this exemption is truly implemented, it would be a significant breakthrough. Currently, both Coinbase and Gemini (in collaboration with Dinari) are actively negotiating with the SEC. Without an exemption, Peirce's statement is almost a "ban"—if she opposes it, then the entire U.S. market is basically hopeless.

But if Atkins does allow the exemption, will other countries' securities regulators follow suit? It remains unknown, but if the U.S. takes the lead in relaxing regulations, it would effectively open the door for global tokenization, which would undoubtedly be a huge leap for the industry.

The European Union is facing the same issue: if the U.S. SEC does not allow stock tokens to be freely traded on-chain, European regulators may use this as a reason to oppose the practices of Gemini and Kraken, especially since the on-chain withdrawal mechanism touches on the gray area of cross-border regulation.

In the past, I was quite pessimistic, but seeing the news that the SEC might relent gives me hope that things may turn around. The key lies in whether the exemption can truly be implemented and how the specific scope of the exemption is defined.

Robinhood's current first phase—pure CFDs hedged with underlying stocks—is compliant, safe, but not on-chain. They clearly hope to enter the second phase, achieving true stock tokenization on-chain. Whether this can be realized depends entirely on Atkins' subsequent statements.

Overall, stock tokenization is currently at a critical point in the global regulatory game. Once the U.S. loosens its stance, whether Hong Kong can synchronize reforms and break the institutional barriers of the Hong Kong Stock Exchange is also worth our continued attention.

The Rise of RWA: Differences Between Hong Kong and the U.S. Market and Future Development Opportunities

Colin: Let's talk about RWA again, especially the development of RWA in Hong Kong. You are currently working in this area; what promising market opportunities are worth paying attention to?

Zheng Di: I believe there are significant differences in the development of RWA between the U.S. and Hong Kong. The main assets in the global English-speaking RWA market are not money market funds, but private placement bonds. The advantage of private placement bonds is that they do not require market price monitoring, and their prices are stable, making them popular among macro hedge funds and fixed-income funds. As long as they do not default, they can record stable returns, which may be why they have become the largest category of RWA.

Currently, the mainstream assets in the U.S. RWA market are government bonds and money market funds. Approximately $7.3 billion in money market funds have been tokenized globally, with BlackRock's BUIDL accounting for $2.8 billion. In contrast, non-standard assets such as real estate and infrastructure have also been tokenized, but they are not mainstream.

Looking at Hong Kong, compliant RWA for non-standard assets may actually become mainstream. For example, the Hong Kong government's 2.0 policy document mentions projects like solar panels and charging stations, which are not commonly seen in the U.S. market, indicating a significant difference in strategies between the two regions.

However, under the overarching trend of "everything on-chain," the market potential is enormous. Michael Saylor (co-founder of MicroStrategy) stated during an SEC investigation in February this year that excluding Bitcoin, the total market value of on-chain assets could increase from the current $1 trillion to $590 trillion. This enormous potential is the main logic driving ETH, Solana, and the MicroStrategy companies behind them.

Nevertheless, both Hong Kong and the U.S. face a common issue—liquidity in the secondary market. Currently, Hong Kong does not allow RWA to be freely transferred in the secondary market. Even if assets can be compliantly tokenized on-chain, if they cannot circulate, their value is difficult to realize. For instance, whether domestic or foreign assets, as long as they are tokenized within a BVI (British Virgin Islands) or Cayman fund structure, they may lack liquidity. Particularly, if domestic assets need to be liquidated abroad, they require QDLP (Qualified Domestic Limited Partner) quotas.

If the liquidity issue can be resolved, it will open up a vast market space. Many institutions are currently researching solutions. In the U.S., some on-chain money market funds can be transferred on-chain via a whitelist, but this is still rare in practice. Once implemented, it will be an important step towards everything being on-chain.

Hong Kong is now focusing more on the on-chain transfer of money market funds (TMMF), especially in the qualified investor zones of licensed exchanges like HashKey Pro. If successful, this will be the first time globally that such transfers are realized within a compliant framework, which would be groundbreaking.

However, there are still some key issues that remain unresolved, such as investor protection mechanisms. If an RWA token is sent to the wrong address or stolen by hackers, there is currently no compensation mechanism. How to provide insurance support for these tokens has become a threshold before regulatory advancement.

Despite this, the overall trend is clear: everything on-chain is the direction of the times. The SEC also realizes that the current STO (Security Token Offering) process is complex and is working to simplify it. SEC Chairman Atkins has stated that the Trump administration aimed for the U.S. to become the cryptocurrency capital, but if retail participation cannot be achieved, it is meaningless. Currently, the Reg A compliance path has only approved four STO projects, indicating that it is overly complex.

Therefore, the SEC's goal is to launch a simplified, low-threshold STO issuance process. Michael Saylor has also emphasized that if the U.S. wants to become a leader in the digital economy, it must address regulatory barriers and allow the market to grow from $1 trillion to $590 trillion. In the next two to three years, there may be results, and even a significant breakthrough could occur next year.

By then, whether Hong Kong will also follow suit remains to be seen. I believe technology is no longer the issue; the core barrier is regulation, and the key lies in finding innovative solutions to break through policy bottlenecks.

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