Author: Meng Yan's Thoughts on Blockchain
On December 17, 2025, HashKey (3887.HK) successfully listed on the Hong Kong Stock Exchange. The listing of HashKey is at a historical crossroads. On one hand, the United States is vigorously advancing the compliance of the crypto economy, with Wall Street poised for action, and the trillion-dollar RWA industry is ready to take off. On the other hand, at the end of November, the People's Bank of China, along with thirteen departments, once again vowed to crack down on virtual currency trading speculation. In this contradictory moment, HashKey's listing has sparked a lot of emotional interpretations within the industry. Whether positive or negative, everyone agrees that this event is not merely a bell-ringing moment for a company, but also an indicator event for the Asian crypto asset industry moving towards "normalization." HashKey thus becomes an extremely rare observational sample in the Asian crypto narrative.
I just saw a letter written by Dr. Xiao to all HashKey employees, in which he said, "This is the hardest road, but we have walked it together." Reading this, I felt quite emotional. I have known Dr. Xiao Feng, the founder of HashKey, for many years; he is a senior and innovator in the financial industry, as well as a thought leader in the global blockchain industry. We share many common ideas and values, and in many ways, he is my teacher. Over the years, I have closely followed HashKey's development and deeply understand the perseverance and difficulties Dr. Xiao has faced in the Wanxiang blockchain for over a decade. Today, having finally achieved a phased success, I sincerely feel happy for Dr. Xiao and all the friends at HashKey.
However, this is not a public relations piece, and I have no intention of adding a congratulatory note for HashKey. I would rather provide a cold and cautious perspective at this moment. Recently, HashKey's prospectus was released, and there has been much interpretation and discussion in the market. The data is honest: while revenue has exploded, it is also accompanied by losses due to high compliance costs and R&D investments. Many people are asking, with HashKey bearing the high costs of compliance and waving the banner of long-termism, what exactly is it aiming for? Will its prospects be bright?
This is indeed an important question, not only concerning HashKey itself but also the overall direction of the Asian crypto industry. I would like to analyze the deep logic and challenges behind HashKey's listing from five dimensions.
1. Reconstruction of the Asset Side—Can HashKey Bring Quality RWA Assets on Chain?
Currently, the biggest narrative in the entire crypto industry is RWA. After the passage of the market structure bill in the United States in the first quarter of next year, trillions of dollars in RWA assets will be rapidly moved on-chain. This means that in the second half of next year, or at the latest by 2027, you will be able to use stablecoins to invest in U.S. stocks, U.S. bonds, and various financial assets on-chain. SEC Chairman Gary Gensler has repeatedly reminded the public that the significance of this event is comparable to the birth of paper securities and the electronicization of securities; it is a major event in human financial history, akin to a "movable type printing" level change. However, not only the public but even financial professionals seem largely indifferent to this. Mainland China has just expressed its stance, deciding to guard against this trend strictly and not yield an inch, dragging it out for as long as possible. But outside of China, the entire Asia still has a vast asset scale, hundreds of billions of dollars in funds, and countless excellent entrepreneurs. In the face of the imminent RWA wave, Asia needs a response.
Looking across Asia, the only one that has taken a compliant stance to positively respond to the RWA challenge is HashKey.
What will HashKey do?
One approach is actually the simplest and safest—become a compliant distribution channel for U.S. RWA assets entering Asia.
In this model, HashKey's main task is to bring RWA products that have already completed structural design, legal qualification, and risk pricing in the U.S. into the Asian market within a compliant framework, providing trading, custody, and settlement services. U.S. stocks, U.S. bonds, ETFs, and even more complex structured products can circulate on-chain in the form of tokens or digital assets.
The benefits of this path are obvious: clear asset quality, mature regulatory logic, and an existing pricing system. HashKey plays more of a role as an "onshore compliance entry point," with high certainty in its business model and relatively controllable execution risks. HashKey occupies a unique geographical position in Hong Kong. The prospectus disclosed a key detail: HashKey has established cooperation with 39 traditional brokerages through Omnibus accounts. This means that millions of traditional Hong Kong stock accounts can theoretically connect seamlessly to crypto assets. This is a smart B2B2C approach that directly leverages the traffic channels of traditional finance.
But the problems are equally apparent—this is a low-risk, low-ceiling path.
In this model, Asia is only technically connecting to U.S. financial assets but is not participating in the core shaping of this round of asset paradigm shift in RWA. The power to define assets, set rules, and narrate finance remains firmly in the hands of Wall Street and the U.S. regulatory system. HashKey ultimately resembles a compliant "distributor" rather than an infrastructure builder for the RWA era.
We must also consider a question: under the current international landscape of U.S.-China competition, how high is the regulatory tolerance for doing a marketplace for U.S. assets in Hong Kong? How high is the ceiling for business?
Another approach, however, is much more difficult and closer to a true "reconstruction of the asset side"—drawing on Wall Street's experience to foster a batch of local Asian RWA assets, completing the full path of compliance on-chain, pricing, and trading.
This means that HashKey is not just introducing ready-made assets but must deeply participate in asset selection, structural design, information disclosure, compliance connection, and secondary market liquidity cultivation. In other words, it needs to help Asian assets become RWA rather than just "selling others' RWA."
The challenges of this path are immense.
First, there are no clear legislative and regulatory rules. Second, local Asian assets generally lag behind U.S. assets in terms of transparency, standardization, legal enforceability, and cross-border regulatory coordination; at the same time, this model also means higher compliance costs, longer cultivation periods, and inevitably low liquidity and high uncertainty in the early stages. From the perspective of short-term financial returns, this is not a "listing company-friendly" path.
However, if viewed from a longer time scale, this is precisely the critical watershed that determines whether HashKey can upgrade from a "compliant trading platform" to "Asian RWA infrastructure."
If Asia remains absent from the discourse power of the asset side in the RWA era, then even if on-chain trading flourishes, it will ultimately just be a marketplace for U.S. assets. Conversely, if a replicable, auditable, and scalable local Asian RWA on-chain paradigm can gradually be established, then HashKey's role will no longer just be to follow trends but to participate in defining them.
Of course, reality does not necessarily have to be either/or.
HashKey is likely to simultaneously advance both paths for a considerable period: on one hand, gaining scale and cash flow by introducing U.S. RWA assets, and on the other hand, tentatively promoting compliance on-chain experiments for Asian assets in a smaller scope. But it must be acknowledged that what truly determines its long-term industry position is not which path is faster, but which path goes further.
RWA is a revolution of the asset side, not a product innovation.
Whether HashKey can play a role beyond "channel" in this revolution is the most worthy question to be continuously observed after this listing.
2. Asset Selection Rights—Can HashKey Incubate a Batch of Sustainable Quality Projects?
Almost all exchanges have told the story of "ecosystem building," but the historical results have not been ideal.
The reason is simple: the incentive mechanism of exchanges naturally favors short-term liquidity rather than the long-term success rate of projects.
What sets HashKey apart is that it bears stronger compliance and disclosure pressures, which theoretically would suppress "quick pump-style incubation." But the question is, can a highly compliant environment still nurture truly networked and spontaneously growing Web3 projects?
If it can only incubate low-volatility, low-narrative, low-risk projects, the ecosystem may be safer but could also be more mediocre. This is a structural tension that all "compliant exchanges" will face.
In offshore markets, exchanges often act as both referees and athletes, with the logic of listing filled with interest transfer and short-term speculation. Since HashKey has chosen the onshore compliance route, it is destined not to follow this old path.
HashKey has a unique "full ecosystem closed loop": from VC investment in the primary market to asset management in the secondary market, and then to liquidity support from the exchange. This structure gives it strong asset selection and pricing capabilities. But I am more concerned about whether it has the courage to say "no" to low-quality assets.
In Dr. Xiao Feng's letter, he mentioned the need to "set a true long-term example for the entire industry." This means HashKey needs to maintain strategic determination in a market filled with high volatility and high multiple temptations, incubating and supporting those truly grounded Web3 native projects with business loops. This requires not only vision but also the ability to resist the temptation of short-term profits. For investors, whether HashKey can become the "asset filter" for the Asian market is a key indicator of its core competitiveness.
3. Experiment in Value Distribution—Can HashKey Explore New Token Economic Models?
Many may not realize that HashKey's listing has created a world first: it is the first company in the world to issue its own token ($HSK) and list on mainstream capital markets. This means HashKey is trading on both the stock market and the token market: HashKey Group is a listed company (3887.HK), representing shareholder interests, pursuing profits and dividends; while its underlying ecosystem, HashKey Chain, and platform token HSK represent community and ecological interests.
This brings a highly experimental point of interest—how does a listed company simultaneously operate a token economy? In the Web2 era, shareholder interests are paramount; in the Web3 era, community consensus reigns. How will HashKey balance these two? The prospectus shows that in 2024, it confirmed an HSK incentive cost of HKD 177 million, which directly affects the profit performance of the current financial report.
This is a difficult balance and a potential innovation. If HashKey can design a mechanism that allows the equity value of the listed company and the token value of the on-chain ecosystem to form a positive feedback loop rather than an exclusive relationship, it will explore a new paradigm for global Web3 companies going public and provide a highly demonstrative case for global listed companies adopting token economics. Conversely, if not handled well, it may face dual pressures from traditional stock market investors (demanding profits) and crypto community users (demanding incentives).
I have had many in-depth discussions with Dr. Xiao Feng on the topic of token economics and token value, and I know well his persistence and belief in this direction, as well as the significant resources and energy he has invested in thinking and practice. I look forward to HashKey making a groundbreaking breakthrough in this area.
4. Good People Must Win—Can HashKey Achieve Commercial Success Within a Compliance Framework?
"Being a good person" has never been an easy task in the crypto world, especially when your competitors are a group of wild, unrestrained offshore giants.
"Compliance" is not only HashKey's most expensive moat but also its current heavy financial shackles. The prospectus shows that in the first half of 2025, compliance costs alone reached HKD 130 million in just six months, which directly exacerbated the net outflow of operating cash flow. This data starkly reveals the cost of being a "regular army"; compliance is not a one-time entry ticket but a state of continuously burning cash flow.
But the problem is: compliance does not automatically translate into commercial success.
The capital market is brutal; it only rewards winners, not "good people." If HashKey merely achieves compliance but fails to convert this compliance advantage into excess commercial returns, then it becomes an expensive and inefficient financial conduit.
Therefore, the core of this perspective lies in: Can HashKey transform "compliance costs" into "compliance premiums"?
We must confront a structural risk: compliance brings higher fixed costs and lower strategic flexibility. While offshore exchanges can freely list high-heat meme coins and offer high-leverage derivatives, HashKey must navigate between different jurisdictions such as Hong Kong, Bermuda, and Japan, responding to increasingly stringent anti-money laundering (AML) and KYC requirements. Will this "dancing with shackles" posture cause it to fall behind in the cycles of technological or model transformation?
If compliance ultimately becomes merely an administrative burden, leading HashKey to become a traditional bank cloaked in blockchain, losing the efficiency and innovation that crypto should have, then this is not "good people winning," but rather "good people being stifled by regulation."
For HashKey to truly "win," it must prove that for traditional financial giants like BlackRock and Fidelity, HashKey is the only channel they dare to use to enter Web3. Only when compliance becomes an exclusive advantage that attracts trillions of traditional funds will those expensive compliance costs be seen as a necessary cornerstone for building monopolistic barriers.
Therefore, the real question worth observing is not whether HashKey will be "stuck" by regulation, but whether it can form a positive interactive relationship with regulation: on one hand, meeting the ever-increasing compliance requirements, and on the other hand, still retaining the core advantages of the blockchain system in efficiency, transparency, and global accessibility.
Dr. Xiao Feng mentioned in his letter that he chose "the hardest road." But the endpoint of this road cannot merely be a moral high ground; it must be a commercial victory. After all, only when good people win can this industry believe in the power of rules, believe in long-termism, and believe in value.
5. Regional Demonstration—Can HashKey Explore a Path of Crypto Long-Termism for Asia?
Finally, we must trace back the genes of this "unicorn." HashKey did not emerge out of nowhere; it is backed by Wanxiang Group's over ten years of deep cultivation in the blockchain field.
From Wanxiang's early investment in Ethereum a decade ago to HashKey's listing today, this is not just a business story but a long technological expedition. This "industrial capital + technological faith" background determines that HashKey is fundamentally different from those offshore exchanges that purely chase traffic. In Dr. Xiao Feng's view, blockchain should not merely be a tool for financial speculation but should serve as the infrastructure for reconstructing the digital economy.
Under the special framework of "one country, two systems," Hong Kong is not only China's financial firewall but also a sandbox for institutional innovation. HashKey's mission is, in fact, answering a long-standing question troubling the Asian economic circle: What kind of Crypto does Asia really need?
Chinese players have an absolute advantage in the offshore exchange field, but after more than a decade, this system has lost its ability to create quality assets and has become mired in controversy and blame.
HashKey is exploring a long-termism path with Asian characteristics.
The "tokenization" business mentioned in the prospectus is the specific carrier of this path. HashKey attempts to prove that under a strict regulatory framework, blockchain technology can still create significant incremental value, rather than merely engaging in speculative zero-sum games with existing funds.
If HashKey can successfully run this model, it will provide an extremely important template for the entire Asian and even global market: compliance is not the opposite of innovation but a prerequisite for large-scale commercial applications.
The road ahead remains that "hardest road." As Dr. Xiao Feng stated in his letter, HashKey did not choose a "more accessible" model but opted for "using technology as a bridge and compliance as a foundation." We should even reasonably expect that HashKey can participate in the shaping and continuous construction of the Asian crypto regulatory system through positive interaction with regulators.
HashKey needs to navigate the narrow path between the arrogance of traditional finance (not understanding Web3) and the wildness of the crypto world (looking down on compliance). This is not only for its own commercial success but also to prove to Asia and the world that after the bubble bursts, the right path is indeed arduous.
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