Author: Wu Says Blockchain
In this episode of the podcast, we invite Hong Kong senior compliance lawyer Wu Wenqian to provide an in-depth analysis of the newly effective stablecoin legislation in Hong Kong, clarifying multiple misunderstandings in the market. He points out that foreign stablecoins like USDT and USDC are not issued in Hong Kong, and therefore are not subject to the new regulations; Hong Kong can still conduct OTC trading of mainstream stablecoins. The discussion also covers retail participation, KYC requirements, regulatory approval processes, the background of large institutions like JD.com entering the market, and the strategic responses of banks and traditional enterprises. Additionally, it analyzes the challenges in applying for stablecoin licenses, the adaptation challenges of the legislation to compliance scenarios, and the differences in crypto policies between Hong Kong and the United States, while looking forward to the development potential and limitations of stablecoins in Hong Kong.
For the complete audio, please search for Wu Says on mainstream audio platforms like Xiaoyuzhou to listen. This article does not constitute any investment advice, and the author's views do not represent Wu Says. Readers are advised to strictly comply with the laws and regulations of their location.
Clarifying Misunderstandings: Regulatory Scope of Stablecoin Regulations and Relationship with Foreign Projects
Colin: Welcome, Lawyer Wu, to our podcast. Lawyer Wu has previously served as the legal and compliance head at OKX and Huobi, and is very familiar with Hong Kong's compliance policies. Recently, the stablecoin legislation in Hong Kong was officially announced, attracting significant attention and controversy. There has been much discussion in society regarding many details of this legislation, especially concerning whether foreign stablecoins will be prohibited from circulating in Hong Kong, and the requirement in the legislation that every holder must complete KYC, which has also sparked considerable debate. Therefore, we invited Lawyer Wu to interpret this for everyone.
Lawyer Wu has previously communicated with me that he believes there are many misunderstandings about this legislation. Let's first ask Lawyer Wu to introduce what he considers the core misunderstandings.
Lawyer Wu: Thank you, Colin, for giving me this opportunity to explain these misunderstandings about the stablecoin regulations. Here’s the situation: the stablecoin regulations in Hong Kong officially came into effect on August 1. Recently, I have encountered many people in the crypto space and the industry who are worried about some issues. The first is whether USDT and USDC will be banned in Hong Kong. So first, I need to explain what this regulation actually supervises. This regulation supervises stablecoins issued in Hong Kong. In other words, if your company or entity issues stablecoins within Hong Kong, you fall under the regulatory scope; the second situation is if you issue stablecoins outside of Hong Kong, but the stablecoin is pegged to the Hong Kong dollar and maintains its stable value, that also falls under the regulatory scope; the third situation is if the regulatory authority determines that the coin you issued falls under the category of stablecoins, it will also be included in the regulation.
The key point to clarify is: only stablecoins issued in Hong Kong, or stablecoins that are pegged to the Hong Kong dollar to maintain their stable value, fall under the regulatory scope. Based on this standard, Tether's USDT and Circle's USDC do not need to apply for a license in Hong Kong. First of all, they are not issued in Hong Kong, they have no employees or offices in Hong Kong, and they are not pegged to the Hong Kong dollar, so they do not fall under the regulatory scope and do not need to obtain a license from Hong Kong.
This is the first misunderstanding. The second misunderstanding is the belief that trading USDT and USDC in Hong Kong has been banned, meaning that USDT or USDC cannot be traded at all in Hong Kong. But as I just mentioned, the regulation supervises the "issuance of stablecoins." Here, "issuance" refers to the initial registration of stablecoins on the blockchain, which is commonly referred to in the crypto space as "minting," and not trading behavior. Therefore, conducting OTC trades of USDT and USDC in Hong Kong does not fall under the issuance behavior.
Thus, trading USDT and USDC in Hong Kong's OTC market is not within the regulatory scope of this legislation. Although Hong Kong may establish a licensing system for the OTC market in the future, as customs have previously discussed this issue, currently, the OTC license has not been issued, and at this stage, the stablecoin regulations do not cover OTC trading.
The third point is about the authority of the Monetary Authority to formulate regulations. There is a notion that the Monetary Authority can arbitrarily define certain behaviors as stablecoin issuance, but that is not the case. Even if the Monetary Authority believes that certain behaviors constitute stablecoin activities, it must follow the statutory procedures, complete announcements and registrations in Hong Kong, and only after the objection period can it take effect. This indicates that the Monetary Authority cannot arbitrarily define which behaviors require a license; otherwise, it would be overstepping its authority.
The fourth point is whether something is recognized as "issuing stablecoins" in Hong Kong depends on multiple factors, such as: Is the management team operating in Hong Kong? Is the issuer or company registered in Hong Kong? Are the maintenance, clearing, or burning activities of the stablecoin occurring in Hong Kong? Are the reserve assets denominated in Hong Kong dollars and stored in Hong Kong banks? All these factors determine whether a project is recognized as issuing stablecoins in Hong Kong. Therefore, I believe there are many misunderstandings about stablecoin regulation that need further clarification.
Regulatory Gap: Uncertain OTC Trading Authority, Retail Trading Becomes Controversial Focus
Colin: So, Lawyer Wu, do you believe that until the OTC legislation is introduced, USDT and USDC can still be used or traded in Hong Kong, right?
Lawyer Wu: Yes, a simple example is that you can see USDT is still tradable on the HashKey platform. HashKey is a licensed virtual asset trading platform (VATP), and currently, USDT can be traded normally on this platform without any issues.
Colin: Understood. What do you think the future OTC legislation might look like in terms of regulating these two mainstream stablecoins?
Lawyer Wu: There is no conclusion yet. Looking back at history, customs conducted a consultation in 2023, and about six months later, a summary report was released. However, in recent months, regulatory authorities have restarted consultations regarding OTC. So the current situation is that the Hong Kong government has not yet determined whether customs or the Securities and Futures Commission (SFC) will regulate OTC.
Previously, I spoke with some people from customs and relevant government officials, and one possibility is that both sides will regulate OTC businesses. On one hand, retail OTC services like exchange shops commonly seen in Hong Kong may be regulated by customs; on the other hand, if it involves self-purchase OTC behaviors, such as online platforms facilitating trades, it may be regulated by the Competition Commission (i.e., the pricing committee). But currently, there is no clear conclusion on this.
So as of now, we still do not know whether OTC trading will be allowed for USDT and USDC. The biggest question is who the trading counterparties are—if they are professional investors or institutional traders, then there is basically no problem; they can engage in such trades.
But the key regulatory focus is retail investors. Whether retail investors can trade USDT and USDC is still a question mark. Previously, customs' consultation direction was to prohibit retail trading of these two stablecoins. However, when we participated in the consultation, we expressed concerns to various people in the crypto space and some compliance experts: if the future OTC license does not allow trading of USDT, the entire licensing mechanism in Hong Kong will be marginalized. Because currently, the largest trading volume still comes from USDT and USDC, if retail investors cannot trade under OTC, it will impact Hong Kong's positioning as an international crypto financial center and the effectiveness of these licensing systems.
So up to now, whether retail investors can trade USDT under the licensed mechanism is indeed undecided. Personally, I hope it can be allowed because if trading is not permitted, the impact will indeed be very significant.
Colin: Right, but from the current perspective, the situation seems rather pessimistic. I feel that the regulators are still quite conservative regarding restrictions on retail investors. You see, only four types of cryptocurrencies are currently open for retail trading, and popular coins like Solana and BNB have not been approved. Imagining that USDT and USDC will be approved for retail trading also seems a bit difficult.
Lawyer Wu: This is indeed a problem and may be one of the reasons why the OTC license has not been issued yet. I think the Hong Kong government has not yet figured out how to regulate retail access to USDT and USDC. Back in 2023, everyone expected that the licenses would be issued by the end of the year, and there was continuous pushing and consulting, but there has been no clear result. So the issue of retail trading is indeed the most core and sensitive part of the entire regulation.
KYC Controversy: Regulations Not Mandatorily Stated, But Regulatory Practice Favors Closed-loop Models
Colin: Another hot topic, aside from the initial discussion about whether USDT and USDC can be used in the future, is a very significant point of contention regarding whether holders must complete KYC. I believe you have certainly noticed this. Because it seems that in the regulations of the United States, Singapore, or the European Union, there is no explicit mandatory requirement for all holders to complete KYC. If Hong Kong really requires everyone to complete KYC, to some extent, it would cut off the DeFi-related ecosystem, as currently, it is very difficult for DeFi to ensure that every user completes KYC. What is your view on this matter?
Lawyer Wu: In fact, the current regulatory text does not explicitly state that all holders must complete KYC. This point is not written in the regulations. However, in the licensing application process of the Monetary Authority, stablecoin issuers need to first explain their business content and operational model to the Monetary Authority before applying. Only after the regulatory authority understands and approves this content will they provide the application form.
This means that the regulatory authority will judge whether you are suitable for applying for a license based on the business model you submit. For example, if JD.com wants to issue a stablecoin for transactions or settlements within its internal ecosystem, such as buying and selling goods on the JD platform or clearing between merchants, every participant in the transaction must complete real-name authentication on the JD platform.
So in this scenario, every user using JD's stablecoin has already completed KYC. In such a closed-loop environment, I believe the Monetary Authority recognizes this model and considers that JD can issue stablecoins. If there is another business model, for example, if you submit a proposal to the Monetary Authority that aims to use stablecoins in the DeFi ecosystem, emphasizing open trading, anonymous users can freely access, and not identifying the identity of holders—then in this case, I believe the likelihood of the Monetary Authority approving your license application will be very low.
I want to emphasize that this is actually another area where people easily misunderstand. Although the regulations themselves do not have a hard requirement that all stablecoin holders must complete KYC, in practical operations, the Monetary Authority will approve based on the business model you submit. If you cannot prove that your business has sufficient anti-money laundering and anti-terrorism financing capabilities, it will be difficult to get approved.
This actually depends on the business content; it is a "model-oriented" regulatory logic. So to summarize, the text does not explicitly state the KYC requirement, but in the actual approval process, the regulatory authority prefers closed-loop, controllable, and user-verified scenarios.
Large Institutions Eager: Why JD.com, Ant Group, and State-owned Enterprises Are Applying for Stablecoin Licenses
Colin: In fact, the regulations mention a relatively vague statement, including later interviews that also mentioned—unless the license holder can prove to the Monetary Authority their ability to combat money laundering, terrorist financing, etc., the identity of every stablecoin holder should be verified by the license holder or a third-party institution. These contents were later acknowledged in interviews. So I understand that this KYC requirement initially does have a certain degree of compulsion, right?
Lawyer Wu: Yes, that's correct. I do believe that initially, the one or two institutions that could obtain licenses would definitely need to implement a complete KYC process in a closed-loop environment to make it easier to obtain a license; this point is basically indisputable.
Colin: Yes, the current situation in Hong Kong is quite interesting, and you should have noticed it as well. Many banks, including some large Chinese banks, local banks, and several state-owned enterprises, are applying for licenses related to stablecoins. At the same time, large internet companies like JD.com and Ant Group have also joined in. Why is there such high enthusiasm? However, the regulators seem very cautious, and the number of licenses issued does not seem to be very high. There is a feeling that the mainland is very enthusiastic, while the regulatory side in Hong Kong is relatively calm and cautious. What do you think about this situation?
Lawyer Wu: Yes, that is indeed the case. From the current environment in Hong Kong, there are two aspects worth noting. First is the composition of the applicants; many Chinese institutions hope to obtain this license by issuing stablecoins to gain a "legitimacy" entry and secure a relatively formal market position.
I have also seen that many listed companies are not just looking to issue stablecoins; they are more interested in using stablecoins, RWA, and other crypto concepts to hype their stocks. This is a direction that many listed companies are currently pushing. Their operations often involve signing some memorandums of understanding (MOU) to create a market imagination space for upcoming blockchain or stablecoin businesses, thereby attracting investor attention and capital speculation, which are still in the conceptual stage.
However, very few projects can actually implement stablecoin issuance or have substantial business. For example, last year, Hong Kong issued licenses to more than a dozen virtual asset trading platforms (VATP), but so far, the most active one is still HashKey, while other platforms have seen relatively slow user traffic and trading growth.
I recently communicated with several companies that have already obtained VATP licenses, and they generally have a concern: the market size in Hong Kong is too small. If a dozen platforms operate simultaneously, the "market cake" seems insufficient to share, so how can they survive? Therefore, the stablecoin market faces the same issue.
In this context, the regulatory authority's strategy is to conduct a preliminary screening and understanding during the initial application phase, not allowing everyone to apply casually. They must first undergo detailed consultations with the Monetary Authority, and only if they agree that your business model is feasible will they issue the formal application form. Therefore, many people want to apply for stablecoin licenses and pursue this business, but very few can actually enter the substantive application stage, and the process itself is full of challenges.
Comparison of Regulations: Hong Kong's Stability and Conservativeness, U.S. Attractiveness Due to Political Changes
Colin: Understood, Lawyer Wu. You have previously been responsible for global compliance matters for some exchanges. Recently, the U.S. SEC released a very significant statement and article, and many people are comparing this situation with that in Hong Kong. From your perspective, do you feel that Hong Kong's attitude is more conservative compared to the U.S., which has left the industry feeling somewhat disappointed? What is your view on this matter?
Lawyer Wu: I think it is more appropriate to say that Hong Kong's attitude towards this industry has been consistent from the beginning, with little change. Hong Kong has always had a relatively pragmatic style; we do not rush to be at the forefront like some countries by introducing various licenses or policies. Instead, we take it step by step, first conducting consultations and research, and then legislating and establishing licensing systems.
In contrast, the policy fluctuations in the U.S. can be quite severe. For example, after Trump returned to power, the regulatory environment for the crypto industry in the U.S. suddenly became much more lenient. Before Trump regained power, the regulatory atmosphere in the U.S. crypto space was quite oppressive, and many people were very disappointed with the U.S. crypto market.
However, after Trump took office, this environment made a nearly 180-degree turn, and many projects and institutions regained confidence in the U.S. market. This is also why many people have recently turned to the U.S., believing that the environment there is more friendly.
On the other hand, Hong Kong has maintained a relatively stable approach. Our policies and regulatory logic have a certain continuity and do not experience drastic fluctuations due to political situations or public opinion changes. From this perspective, if one is looking at short-term opportunities, the U.S. is indeed more attractive; but from the standpoint of long-term development and regulatory stability, I believe Hong Kong may actually have an advantage.
Looking back two years ago, for instance, Binance was under a lot of pressure, and Coinbase was too; almost all U.S. exchanges were considering exiting the U.S. market. The situation at that time was very unfavorable for businesses, making it difficult for a company with a long-term strategy to operate in such an environment. So I think the short-term outlook may favor the U.S., but in terms of medium to long-term policy stability, Hong Kong still has certain advantages.
Offshore RMB Stablecoins: Different Definitions from HKD Stablecoins, No Current Conflict
Colin: Another focus of attention is the issue of offshore RMB stablecoins. The recently introduced Hong Kong stablecoin legislation does not impose restrictions on RMB stablecoins, right? So what are the essential differences between them and other stablecoins?
Lawyer Wu: In fact, within the framework of stablecoins in Hong Kong, offshore RMB is not considered a stablecoin. This is because offshore RMB is essentially still a national legal currency, just existing in the offshore market, so it cannot be classified as the type of stablecoin we typically understand, which exists in the form of crypto assets and relies on reserves for support.
For example, there has been previous discussion in Hong Kong about issuing E-HKD, which is the electronic Hong Kong dollar. This actually falls under the category of central bank digital currency (CBDC), and it is a completely different concept from stablecoins issued by commercial entities. One is the digitization of a sovereign currency, while the other is a stablecoin supported by an asset reserve mechanism. Therefore, I believe these two are different in definition and function, and currently, they do not seem to have a direct conflict.
Colin: Do you think that under the current legislation, companies like JD.com might issue offshore stablecoins denominated in RMB in the future?
Lawyer Wu: It is hard to say at this point. There may be some overlap between the market for offshore RMB stablecoins and the market for regular stablecoins, but in the current environment, the main issuance target for Hong Kong stablecoins is still those denominated in HKD.
As for whether it will develop into a scenario where HKD and RMB can be traded with each other in the future, that is very likely to happen. However, if it is simply designed as a stablecoin based on offshore RMB for a business model, I believe the regulatory authorities in Hong Kong, especially the Competition Commission, are currently unlikely to accept such a proposal.
This may belong to the exploration direction of the next stage, rather than the current focus of stablecoin issuance. The current policy in Hong Kong is still focused on HKD-denominated stablecoins. HKD stablecoins remain the focus of current development.
Active Participation of Banks: Establishing Teams for Asset Management and Business Expansion
Colin: There is an interesting phenomenon recently where almost all banks have started to establish dedicated teams to work on stablecoin-related tasks. This is quite special because in other regions, such as the U.S. and Singapore, it is usually crypto institutions that lead the development of stablecoins. But now many banks in Hong Kong are entering the field, and from what I understand, they are indeed building teams, whether to prepare for license applications or to explore business directions. Have you noticed this phenomenon? Is there any particular reason behind it?
Lawyer Wu: I believe there are two main reasons behind banks starting to form teams related to stablecoins.
The first is that the new stablecoin licensing mechanism has been introduced, which includes a requirement that if a HKD stablecoin is issued, its reserve assets must be stored within the banking system. In other words, stablecoin issuers must establish cooperation with banks to manage the reserve assets. Therefore, banks must first engage with this industry and understand how it operates to fulfill the role of reserve custody. This is a necessary preparation for banks.
The second reason is market opportunity. We see that in the U.S., USDT (Tether) has a very large market size. If the stablecoin business in Hong Kong can also grow in the future, it will represent a very stable and long-term potential business for banks. For banks, this area of financial services, which is supported by real assets and has strong customer stickiness, holds great commercial appeal.
Additionally, Hong Kong banks are currently facing considerable pressure, such as declining property prices and a sluggish real estate market, along with reduced income from traditional businesses. Naturally, they will want to develop new growth points. In this context, the stablecoin business appears particularly worthwhile to pursue. Therefore, it is a very reasonable and strategically significant choice for banks to actively participate.
Competitiveness Concerns: Hong Kong Stablecoins Target Compliance Scenarios, Hard to Compete with USDT/USDC
Colin: There is also a topic of discussion regarding what you just mentioned, that USDT and USDC have already been very successful. One circulates mainly in developing countries, while the other has a strong market share in compliance scenarios. So, do you think the stablecoins born under the Hong Kong stablecoin licensing system really have competitiveness? Are they only serving users within their own ecosystems, or could they potentially compete with international mainstream stablecoins like USDT and USDC?
Lawyer Wu: I think this question needs to be viewed from the market structure perspective. Currently, the market share of USDT and USDC is very large, and almost all crypto users' transactions are based on these two stablecoins. If a locally launched stablecoin in Hong Kong, such as Meego stablecoin, wants to directly compete with USDT and USDC, it is very difficult, and I think this is beyond doubt.
However, the key lies in the markets and use cases they target, which may be different. USDT and USDC are more geared towards serving traditional crypto users, while stablecoins issued in Hong Kong may lean more towards the development of compliance scenarios.
For example, in the future, if there are some ODBA (On-Chain Digital Bond Authorization) projects or STO (Security Token Offering) projects, these projects may be restricted to only using locally licensed stablecoins for transactions. This would create a completely independent market ecosystem.
Conversely, transactions involving USDT and USDC often lack KYC and real-name processes, which could pose identity recognition and compliance obstacles when used for certain securities transactions, tokenized asset issuances, or scenarios in cooperation with the Hong Kong Stock Exchange. In contrast, HKD-denominated compliant stablecoins may not face these issues.
Therefore, from the perspective of market division of labor, Hong Kong stablecoins may not directly compete with USDT and USDC in the open market, but they could potentially carve out a new track in compliance application scenarios. In this way, Hong Kong's stablecoins can develop their unique positioning.
Exploring Application Prospects: Stablecoins Need to Find Their Positioning in Specific Compliance Scenarios
Colin: Regarding regulated stablecoins, what advantages do you think these stablecoins have compared to traditional payment methods or fiat currencies? For example, as you mentioned, the Hong Kong Stock Exchange may adopt stablecoins in the future. I actually find it hard to understand why they would want to use this; is it really necessary for them? I haven't thought this through yet. What do you think?
Lawyer Wu: Yes, I believe that from the perspective of traditional crypto users, like myself, I would definitely prefer to use USDT rather than a local Hong Kong stablecoin. This is quite normal. For those who have been using digital currencies for the past few years, USDT and USDC have already become the most familiar and commonly used options.
As for Hong Kong's stablecoins, their development will depend on whether they can find their application scenarios in the future. When they were first introduced, the regulatory authority established a "sandbox" mechanism to organize various pilot projects, hoping to explore through some practices—if stablecoins were issued locally in Hong Kong, what kind of business models would develop. These conclusions have not yet been reached.
In the foreseeable future, I believe it is unlikely that Hong Kong's stablecoins will directly compete with USDT and USDC; this is almost certain. As I mentioned earlier, they may need to find their uses and development space in a completely independent track.
However, this also depends on the overall direction of the crypto space. Currently, besides RWA (Real World Asset tokenization) and stablecoins, which are relatively active concepts, the market seems to have lost a clear direction compared to the DeFi Summer of 2020 and 2021, the NFT boom, and the subsequent Meme Coin craze. Especially with the increasing entry of traditional financial (TradFi) institutions, the market has become more conservative.
At present, stablecoins may primarily develop in compliance scenarios, such as LGBA (regulated on-chain asset issuance platforms) and STO (Security Token Offerings). They will form a completely different ecosystem from the traditional crypto space. My personal view is that these two systems should develop in parallel.
The crypto space should continue to maintain its independence and move towards a more decentralized direction, while stablecoins in compliance scenarios represent a completely different development path. In the foreseeable future, I do not see these two merging. Instead, I hope for a "two-legged approach," where each develops its own ecosystem and business direction.
International Anti-Money Laundering Pressure: Could FATF Review Affect Hong Kong's Regulatory Tightening?
Colin: Lawyer Wu, there is another statement I haven't fully confirmed regarding Singapore's recent strict expulsion of unlicensed crypto institutions. It is said that this is due to the FATF, the international anti-money laundering organization, currently reviewing Singapore. This can basically be confirmed. However, there is another claim that the FATF may conduct a new round of assessments on Hong Kong next year. If true, I wonder if this will impact Hong Kong's cryptocurrency policies, especially the strict anti-money laundering requirements in the current stablecoin regulations? What do you think?
Lawyer Wu: I haven't heard this claim yet, but if it is indeed true, I believe it will certainly have some impact. From another perspective, different regulatory agencies in Hong Kong have already become noticeably stricter in their scrutiny of companies, projects, and banking partners involved in the crypto space.
This can be felt in reality; for example, some companies that were quite active in the crypto space in the past have found that the process of opening bank accounts or applying for relevant licenses, which used to be relatively lenient, has clearly become more difficult in the past six months. This change is evident.
I think this tightening is actually reasonable. In the previous phase, regulation was relatively lenient, and many companies and institutions entered this field quite actively and aggressively. But when regulators realized that they might have been too lenient, they naturally adjusted towards a stricter direction. It's like a cycle—once leniency reaches a certain point, problems will arise, leading to a tightening phase; after being too tight for too long and suppressing the market, there will be a moderate loosening.
So I believe that Hong Kong's regulation is currently in this "cycle" of tightening. If the FATF really conducts a new round of assessments on Hong Kong, the regulatory authorities may emphasize the robustness of anti-money laundering mechanisms even more, including stricter requirements for real-name systems, KYC mechanisms, and reserve transparency for stablecoins. This can explain why policies are becoming more conservative in their implementation.
Market Heat Resurgence: Web2 Companies Entering, Hong Kong's Atmosphere Gradually Warming Up but Many Still in Preparation Stage
Colin: Lastly, I want to ask you a question. How do you feel about the Web3 atmosphere in Hong Kong this year? There are rumors that some institutions from Singapore have started to shift to Hong Kong. Have you encountered this situation in your work or life?
Lawyer Wu: Regarding the situation of Singaporean projects coming to Hong Kong, I haven't encountered many yet; there are some, but overall, it's not a lot. On the contrary, I feel that in the last two to three months, the overall atmosphere in Hong Kong has improved significantly compared to the beginning of the year.
Because during the period from the end of last year to the beginning of this year, the atmosphere in the Hong Kong market was relatively cold, almost stagnant, and the activity level in the entire Web3 circle was not very high. However, in recent months, with the introduction and gradual implementation of stablecoin policies, I feel that the market has become relatively vibrant again.
Especially now, many companies that originally operated in Web2, such as some major enterprises and brands, even traditional companies like perfume manufacturers, are starting to plan their entry into Web3, considering issuing tokens, creating digital assets, or engaging in other on-chain businesses.
Overall, Hong Kong is indeed in a phase of warming market enthusiasm, with everyone discussing and willing to participate. But at the same time, it should be noted that most institutions are still in the "imagination stage," meaning they are planning, researching, and conceptualizing, but there are still not many projects that have been truly implemented and executed.
Personally, I actually prefer to see those companies that work quietly, accumulating without making noise, and suddenly presenting a mature product or an independent track. This is the scenario I look forward to seeing. Only when ideas are truly translated into practice can the enthusiasm for Web3 become a real driving force for the industry.
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