Author: Xu Duoqi
Abstract: Stablecoins, serving as a critical bridge between traditional finance and decentralized finance, embody inherent tensions in their attempt to reconcile the decentralized, borderless nature of cryptocurrencies with the stability of fiat currencies. This fusion presents opportunities for financial innovation alongside formidable regulatory challenges.From a comparative law perspective, the United States operates a dual-track regulatory framework involving federal and state authorities, the European Union has pursued harmonized legislative measures, and Hong Kong, China, is developing a balanced legislative sandbox approach.Globally, there is consensus on core principles, including uniform regulation of similar activities, functional equivalence, and multilateral cooperation. However, regulatory conflicts persist across public entities, between public and private entities, and within private entities themselves.Given the misalignment of existing regulatory regimes, it is imperative to establish a governance structure that integrates functional and entity-based regulation, follows a developmental path anchored in the real economy, and reinforces transparency alongside compliance-enabling technologies.Short-term measures—such as establishing baseline norms, implementing functional equivalence supervision, and instituting cross-border risk reporting—can form the foundation of a stablecoin risk management system tailored to China's national circumstances. Such an approach would not only amplify China's voice in global governance but also strike a balance between financial innovation and risk control, thereby promoting the sustainable and compliant evolution of stablecoins.
Keywords: Stablecoins; Risk Prevention and Control; International Regulatory Competition; Discursive Power; Legal Regulation
Journal：Journal of Comparative Law (CSSCI), (5).
Publish date：2025/9/25
