Cobo Stable Weekly No.15 ｜The Great Stablecoin Divide: Regulatory Approaches Across Continents
Stablecoin regulation is heating up everywhere, and the approaches couldn't be more different.
Global payments are undergoing a revolution, and stablecoins are at the heart of this transformation. They're not just reshaping how money moves across borders—they're completely redefining what payments can be. Cobo stands at the cutting edge of this shift, building the full-stack infrastructure that powers next-gen stablecoin solutions: from secure wallet tech to risk control and compliance and yield-generating options that actually make your money work.
Go with Cobo, and you can zero in on building cool stuff and growing your user base, while surfing the stablecoin revolution without the infrastructure headaches.
Global stablecoin regulation accelerates. EU's MiCA launches with 50+ approvals while Hong Kong plans single-digit high-barrier licenses and US GENIUS Act advances federal integration. Rising barriers consolidate issuance to banking-licensed institutions with clearing access.
Infrastructure shifts to service layers. Agora, Cobo package clearing, custody, risk tools into APIs, building composable cross-border execution layers. Capital returns—Circle tops Korean US picks, crypto funding hits $2.8B led by financial services.
Competition evolves from licensing to execution capabilities.
Market Overview and Growth Highlights
Stablecoin Total Market Cap Reaches $257.012b
The total stablecoin market capitalization has reached $257.012 billion, reflecting a week-over-week growth of $2.107b. In terms of market share, USDT continues to dominate with a 62.25% share, followed by USDC, which holds the second position with a market cap of $62.554 billion (24.34% share).
Blockchain Network Distribution
Top 3 Networks by Stablecoin Market Cap:
Ethereum: $127.002B
Tron: $81.395B
Solana: $11.149B
Top 3 Fastest-Growing Networks (Weekly):
Noble：+45.57%（USDC dominance: 68.18%）
Movement：+28.75%（USDT dominance: 25.52%）
Hedera：+20.07%（USDC dominance:99.84%）
Data Source: DefiLlama
🎯From "Single Digits" to "30-Country Passport": Global Stablecoin Regulatory Arbitrage
Stablecoins are becoming critical digital finance infrastructure, and "compliance status" has evolved from defensive necessity to strategic asset.
Europe leads with MiCA's "license once, operate everywhere" passport. 14 stablecoin issuers and 39 crypto service providers got approved—from Coinbase and Kraken to traditional players like BBVA and N26. Unified standards are creating a coherent European crypto market.
Hong Kong takes the cautious route. HKMA launches stablecoin regs in August with single-digit licenses, demanding 100% high-quality reserves with zero active management. Annual returns might hit just 1-3%, barely covering compliance costs, but Hong Kong positions stablecoins as the "settlement currency layer" for on-chain finance.
China's exploring a "dual-track" RMB stablecoin model: Hong Kong as offshore RMB stablecoin hub (CNHC), Shanghai Free Trade Zone for onshore trials (CNYC). The goal is boosting RMB's international utility in DeFi, cross-border payments, and RWA scenarios.
The US lacks federal licensing but the GENIUS Act is pushing stablecoins into national payment infrastructure. Circle and Ripple are chasing federal trust bank licenses to plug directly into Fed clearing networks, positioning for core roles in "digital dollar" infrastructure.
The regulatory landscape is fracturing fast: EU prioritizes market integration, Hong Kong emphasizes risk control, US bets on global clearing dominance. Stablecoin issuers need to map local regulatory paths to their capabilities and find sustainable models. For China, building a regulated, coordinated RMB stablecoin system isn't just responding to global regulatory opportunities—it's a new pivot point for RMB internationalization in the digital era.
🎯 Digital Finance Paradigm Shift: How Licensing Thresholds Are Reshaping Stablecoin Ecosystems
Stablecoins are evolving from simple digital tokens into core infrastructure for next-gen finance. As regulations like the GENIUS Act push issuance toward banking-grade standards—requiring 100% quality reserves and national payment system integration—direct stablecoin issuance has become an "infrastructure-level capability" demanding serious regulatory credentials, capital strength, and financial system access.
This compliance wall locks out most players while pushing crypto giants like Circle and Ripple to chase federal trust bank licenses, positioning for control over future "digital dollar" infrastructure. Direct stablecoin issuance is now a game for well-capitalized institutions with serious licensing chops.
Enter the infrastructure abstractors. Agora's stablecoin operating system breaks down this high-barrier process into modular components—compliance frameworks, custody services, reserve management, on-chain AML, fiat rails, and exchange connectivity. Companies can now deploy branded stablecoins through white-label solutions, focusing on business logic rather than regulatory plumbing.
This represents a shift from "license-holding intermediaries" to "underlying capability platforms." While earlier models like Paxos relied on their own licenses to service third parties, Agora standardizes and networks core modules, opening stablecoin infrastructure to broader institutional access. This lowers entry barriers and creates pathways for stablecoins to become "platform currencies" or "vertical settlement layers."
Cobo's solution exemplifies this "embedded financial infrastructure" evolution. Core functions like clearing, custody, risk management, and on/off-ramps get packaged as standardized modules accessible via APIs. Companies can mix and match capabilities as needed. Trust shifts from institutions to interfaces—think cloud computing replacing on-premise deployments.
On-chain wallets, MPC, and centralized custody ensure compliant fund security. Multi-bank channels and payment networks enable efficient cross-border stablecoin flow. Risk controls and on-chain monitoring introduce regulatory-acceptable behavioral norms. This interface-driven architecture is reshaping stablecoin market logic—issuers no longer need full-stack capabilities but can build service systems on trusted execution layers, making stablecoins truly composable, governable, globally-compatible financial primitives.
🎯 WeChat Pay MCP and the Future of "Machine Money"
On July 3rd, Tencent's Yuanqi platform integrated WeChat Pay MCP, giving AI agents actual payment capabilities. Agents evolved from info providers to economic actors, handling service generation, delivery, and payment in conversations through simple API calls. This marks AI business models entering full automation, opening new commercial pathways for developers.
This echoes global AI commercialization experiments. Anthropic previously let Claude 3 independently run a vending machine operation—it lost money, but performed solidly on restocking, pricing negotiations, and risk management. The failure wasn't algorithmic but structural: misaligned objectives (being "helpful" trumped "profitable"), missing pricing strategies, and lack of order management systems. The experiment proved AI agents have the technical chops; they just need better external infrastructure and authorization frameworks.
Payment systems are the next bottleneck for AI commercial capabilities. Traditional payment rails designed for humans—high fees, slow settlement, inflexible authorization—clash with agents' 24/7 operations, micropayments, and automation needs. Stablecoins emerge as "machine-native currency," naturally fitting agent business logic: ultra-low costs enable granular dynamic pricing; on-chain records and wallet addresses integrate with CRM for user profiling and automated incentives; instant settlement syncs payments with order status, creating end-to-end fulfillment without human intervention.
But AI agents with payment powers also amplify risks automatically. Payment manipulation, fake content monetization, even "AI scamming AI" scenarios could close loops with zero human oversight. Platforms need robust permission management and risk controls—strict developer vetting, payment trigger logic oversight, and anomaly detection. AI agents' economic identity is now active; payment infrastructure security and governance will determine whether this new paradigm gets unleashed safely.
Market Adoption
🌱Circle just teamed up with OKX, letting the exchange's 60 million users seamlessly convert between USD and USDC. This partnership is a big deal for USDC's global reach and liquidity, making it easier for users to transact and pay with the stablecoin. It also underscores Circle's aggressive strategy to bolster its position as a leading stablecoin issuer and enhance USDC's utility in international payments.
🌱Ant International, a subsidiary of Ant Group, is reportedly planning to integrate Circle's USDC stablecoin into its blockchain platform once U.S. stablecoin regulations are finalized. This move is significant given Ant Group processed over $1 trillion in global transactions last year, with a third handled by its blockchain system. The company is also actively seeking stablecoin licenses in Hong Kong, Singapore, and Luxembourg, signaling a major push into the global stablecoin market and highlighting the growing mainstream adoption of stablecoins in international payments.
🌱Meow has partnered with Bridge to become the first US company enabling businesses to send and receive USDC directly on commercial banking platforms. The integration simplifies crypto onboarding, bridges USDC with traditional accounting systems, and offers enterprise-grade controls at lower transaction costs. Results have been impressive: billions in increased transaction volume, tripled customer accounts, 2024 profitability, and accounting processing slashed from hours to minutes. This proves stablecoins can work as seamlessly as cash for everyday business payments.
🌱Australian fintech unicorn Airwallex is building a stablecoin platform to enable global buying, holding, sending, and settling of tokens with near-instant payments and seamless fiat conversions. The $3 billion company is actively hiring engineers for this infrastructure, signaling serious commitment to blockchain-powered cross-border payments. This represents a major convergence of traditional payments and crypto, potentially accelerating stablecoin adoption across Asia-Pacific markets. Airwallex's move could provide their existing global network with more efficient settlement rails.
🌱Visa has partnered with Bridge to launch stablecoin payment cards across Latin America, targeting Argentina, Colombia, and Mexico. The collaboration offers a single API for fintechs and businesses to integrate stablecoin payment services, addressing real-world needs in high-inflation regions. This marks another significant step in Visa's crypto expansion, demonstrating how stablecoins are transitioning from speculative assets to practical payment infrastructure. The Latin American focus highlights stablecoins' utility in markets with currency volatility.
Big Picture
🔮The US national debt has hit a new record high, forcing the government to issue massive amounts of bonds in a high-rate environment, which is driving up interest payments and straining fiscal resources. Facing this debt crisis, the government might encourage compliant stablecoin issuers to increase Treasury holdings, creating a form of "stealth quantitative easing" to boost demand for US debt. This strategy could significantly reshape stablecoin regulations as the government has clear incentives to direct stablecoin reserves into Treasury markets. The move would profoundly impact reserve strategies and compliance requirements for major stablecoins like USDC, potentially making them indirect tools for government debt financing.
🔮Mizuho downgraded Circle stock to "underperform" with an $85 target price versus its current trading level, citing overstated growth prospects. The firm highlights three key risks: upcoming rate cuts, stagnant USDC circulation around $62 billion since April, and declining profit margins from 61% to 39%. Mizuho believes Circle's $4.5 billion revenue target by 2027 is overstated by 25-30%, especially with emerging competition and partners like Coinbase capturing larger market share. This represents a significant shift from retail enthusiasm following Circle's IPO to institutional skepticism about long-term valuation.
🔮South Korea is experiencing a stablecoin registration frenzy with major financial players like Toss Bank, Shinhan, KakaoPay, and KB Kookmin Bank filing trademarks despite unclear regulations. Stock prices typically jump 15-30% when companies announce stablecoin trademark applications, reflecting massive investor enthusiasm. Korean investors poured $410 million into Circle stock in June alone, making it their top foreign investment choice. This nationwide fervor positions South Korea as a pivotal Asian stablecoin market potentially spawning globally influential projects.
New Launches
👀 The GENIUS Act is creating a two-tier stablecoin market where traditional financial institutions dominate issuance while fintechs struggle with liquidity access. Checker is positioning itself as a liquidity service provider, addressing shallow regional liquidity, high compliance costs, and inefficient market expansion for financial institutions. The platform is building a global distribution network through partnerships with players like Blox_globe and GrupoBraza, spanning emerging markets from Lagos to São Paulo. This regulatory-driven market segmentation creates new opportunities where big players handle compliant issuance while specialized providers like Checker focus on efficient global distribution and liquidity solutions.
👀Solayer launched Emerald Sub Cards, allowing users to create multiple virtual cards under one main account with custom labels, spending limits, and transaction tracking for different purposes. Users can now set up separate cards for groceries, family use, friends, or savings goals, making stablecoin payments more versatile for everyday spending. The feature is live at app.solayer.org/card for all Emerald Card holders, bringing crypto payments closer to traditional banking features. This evolution makes stablecoins more accessible for average users and could significantly boost their adoption in daily transactions and household budget management.
Regulation & Compliance
🏛️A hacker swapped $1.3 million USDT0 for USDC in just 23 seconds, beating the USDT0 team's freeze attempt due to blockchain confirmation delays. Circle hadn't responded or frozen the USDC an hour after the incident, raising questions about their security protocols. This becomes a crucial test case for stablecoin issuer coordination and market trust. The incident highlights how blockchain confirmation times can create windows for attackers to escape asset freezes across different stablecoin ecosystems.
🏛️Tether is hoarding 80 tons of gold worth $8 billion in a secret Swiss vault, representing nearly 5% of its total reserves. CEO Paolo Ardoino calls it "the most secure vault in the world" but won't reveal the location for security reasons. The company also issues XAUT, a gold-backed token where each represents one ounce of physical gold that holders can redeem directly in Switzerland. However, this strategy could clash with EU and proposed US regulations that typically only allow cash and government bonds as backing for fiat-pegged stablecoins, potentially forcing Tether to dump its gold to get authorized in major markets.
🏛️Circle signed a revenue-sharing deal with ByBit for USDC reserves, following similar agreements with Coinbase and Binance. This has become Circle's standard playbook for growing USDC adoption across major exchanges. According to insiders, any exchange holding significant USDC basically gets a cut of the revenue. It's a smart strategy that's helped Circle rapidly expand the USDC ecosystem by giving exchanges financial incentives to push their stablecoin.
🏛️ Hong Kong's groundbreaking stablecoin regulations go live August 1st, creating the world's first comprehensive framework for fiat-pegged stablecoins. The framework has already sparked major interest from mainland China's A-share companies as investors quiz them about stablecoin strategies. Early results are promising - tokenized green bonds already cut settlement from T+5 to T+1, showing real efficiency gains. This sets a crucial benchmark for Asia's digital asset development and could accelerate RMB-backed stablecoin projects while mainland policymakers watch closely for lessons.
🏛️Six months into MiCA, Europe has 14 authorized stablecoin issuers across seven countries launching 20 stablecoins, plus 39 licensed crypto service providers spanning traditional banks, fintechs, and native crypto firms. The mix includes 12 Euro-pegged, 7 USD-pegged, and one Czech Koruna stablecoin, with zero Asset-Referenced Token approvals showing limited demand for that category. This rapid adoption demonstrates Europe's lead in creating unified regulatory frameworks where traditional finance and crypto companies compete on equal footing. It's becoming the global playbook for stablecoin regulation as the industry matures.
🏛️Dubai approved the QCD Money Market Fund, backed by Qatar National Bank and DMZ Finance, marking the first approved tokenized money market fund in the region. The fund aims to bring traditional assets onto blockchain for institutional use cases, positioning the Middle East as a digital asset financial hub. A joint report projects the global tokenized real-world asset market to reach $18.9 trillion by 2033, with Dubai and Doha expected as early leaders. This approval represents a major breakthrough for RWA tokenization, demonstrating the Middle East's proactive approach to building digital asset financial infrastructure and creating new investment opportunities for institutional investors by bridging traditional finance with blockchain technology.
🏛️Orbiter Finance partnered with Nasdaq-listed Nano Labs to launch NBNB io, a compliant stablecoin cross-chain platform supporting USD, HKD, and offshore RMB transfers set for Q4 2025. The collaboration targets compliant stablecoin adoption within BNB Chain's DeFi ecosystem, marking a major step toward mainstream finance integration. The addition of HKD and offshore RMB stablecoins gives Asian users more digital asset options while boosting BNB Chain's growth.
🏛️ China's National Institution for Finance & Development is proposing an "internal and external" RMB stablecoin strategy, with deputy director Yang Tao suggesting concurrent development in Shanghai's Free Trade Zone and Hong Kong. The proposal outlines two models for an offshore RMB stablecoin (CNYC): a multi-institutional issuing body in Shanghai or direct issuance by the digital yuan entity. The paper argues that Web3.0-based stablecoins transcend traditional offshore/onshore boundaries and recommends collaborative development between the digital yuan and stablecoins, drawing from the BIS's "unified ledger" concept. This systematic approach by Chinese official think tanks signals strategic planning for RMB stablecoin development, emphasizing institutional innovation and regulatory frameworks to support China's digital finance evolution and RMB internationalization goals.
Capital Moves
💰Revolut is reportedly raising $1 billion at a $65 billion valuation (44% increase from last year) with Greenoaks leading the round, while secretly developing its own stablecoin. With 50 million users, banking licenses in 30+ countries, and the Revolut X crypto exchange, the company has a powerful distribution network that could bypass traditional channel fees and boost margins significantly. Unlike existing stablecoin issuers, Revolut's integrated financial infrastructure and massive user base could reshape the industry by setting new standards for compliance and innovation. This move would leverage their super-app ecosystem to directly challenge established players in the stablecoin market.
💰Agora raised $50 million in Series A funding led by Paradigm for its white-label stablecoin services, following a $12 million seed round. The company enables businesses to launch branded stablecoins built on top of Agora's AUSD, providing shared interoperability and liquidity. Agora differentiates itself by sharing revenue from USD reserves with partners and works with State Street and VanEck for reserve management, with AUSD currently at $130 million market cap. With tech giants like Meta and Apple exploring stablecoins, Agora's revenue-sharing model and cross-border payment focus could capture significant market share, particularly in non-US regions where USD volatility is a major concern.
💰Tether invested in blockchain analytics firm Crystal Intelligence to enhance real-time risk monitoring, fraud detection, and regulatory intelligence for combating USDT-related crimes. With the FBI reporting $9.3 billion in digital asset fraud losses last year, stablecoins have become attractive to criminals due to their widespread adoption. Tether and Crystal Intelligence already launched the Scam Alert public database to flag fraudulent wallet addresses and improve transparency. This strategic investment demonstrates Tether's proactive approach to fighting illicit activities amid intensifying regulatory scrutiny and prepares the company for increased global oversight while protecting users from crypto-related fraud.
💰Crypto VC funding surged to $2.8 billion in June, nearly matching March's $2.9 billion high after a sluggish May. Major raises included Kalshi's $185 million Series C, Digital Asset's $135 million, and Zama's $57 million, plus significant token purchases like the UAE's $100 million in World Liberty Financial and a16z's $70 million in EigenLayer. While AI projects were most numerous with 21 deals raising $116 million, financial services dominated capital flows with $1.15 billion across just 5 projects, followed by infrastructure at $881 million. The data shows a shift toward mature, later-stage funding rounds and continued investor confidence in core crypto financial infrastructure, particularly following Circle's public listing success.
💰The Monad Foundation acquired Portal, a stablecoin infrastructure provider, and brought on Raj Parekh from Visa's crypto team as Head of Payments and Stablecoins. Monad's blockchain in public testnet has processed 2 billion transactions in five months with peak speeds of 10,000 TPS, designed to handle stablecoin payments for hundreds of millions of daily users. Portal will continue operating independently, providing plug-and-play tools for Web2 businesses to integrate crypto payments. This acquisition combines high-performance blockchain infrastructure with established stablecoin settlement capabilities, addressing technical bottlenecks that have limited widespread adoption while offering low-cost transactions and developer-friendly integration tools.