Abstract: As a critical bridge between traditional finance and decentralized finance, stablecoins embody inherent tensions by attempting to combine the decentralization and borderless nature of cryptocurrencies with the stability of sovereign fiat currencies. While creating opportunities for financial innovation, they simultaneously pose significant regulatory challenges. From a comparative law perspective, the United States adopts a dual-track regulatory framework at the federal and state levels, the European Union advances a unified legislative approach, and Hong Kong, China explores a balanced strategy through regulatory sandboxes. At the international level, a degree of consensus has emerged around principles such as same activity, same regulation, functional look-through regulation, and multilateral coordination. Nevertheless, regulatory conflicts and strategic interactions persist among public authority and private power, between private power and private rights, and among public authorities themselves. In light of the mismatches within existing regulatory regimes, it is necessary to establish a governance framework that integrates functional regulation with entity-based regulation, reorients stablecoin development toward the real economy, and strengthens transparency and compliance-oriented technological applications. By adopting near-term measures such as formulating lower-level regulatory instruments, implementing functional look-through supervision, and establishing cross-border risk reporting mechanisms, China can build a stablecoin risk prevention and control system aligned with its national conditions. Such efforts would enhance China’s discursive power in global governance, achieve a balance between financial innovation and risk mitigation, and promote the sound and orderly development of stablecoins within a compliant regulatory framework.
Keywords: Stablecoins; Risk Prevention and Control; International Regulatory Competition; Discursive Power; Legal Regulation
Author：Xu Duoqi
