Zhang Jianhua: Discussion on the Necessity and Feasible Path of Renminbi Stablecoin

Zhang Jianhua pointed out that stablecoins are not legal tender; they are a "quasi-currency" that possesses various core attributes of currencies. The necessity and strictness of their regulation should be far greater than that of ordinary investment products. Stablecoins rely on blockchain technology, which brings efficiency improvements but also significant risks and regulatory challenges, especially issues related to anonymity that raise concerns about anti-money laundering, counter-terrorism financing, and transparency. To meet regulatory requirements through technological advancements, there also needs to be a consensus on regulatory tolerance among multiple countries to achieve cross-border cooperation.

Zhang Jianhua analyzed that cross-border payments and RWA investments are the main directions for the future development of stablecoins, with the latter potentially offering even greater opportunities than cross-border trade. For the RMB system, it is of strategic importance to cautiously explore stablecoins, especially offshore pilots, as a necessary measure to address the challenges of the digital currency era and to maintain monetary sovereignty and financial competitiveness.

Function Positioning of Stablecoins: A "Quasi-Currency" Between Currency and Payment Tools

Regarding the future of stablecoins, Zhang Jianhua believes it depends not only on market application demands and calls but also on how regulatory authorities define their nature. Previously, crypto assets experienced a period of wild growth, after which regulatory bodies completely banned and eliminated them. Currently, globally, the development of stablecoins is showing a trend of moving from an early unregulated free state to a gradual intervention by regulatory authorities imposing various regulatory requirements. When discussing the development of stablecoins in China, it is essential to recognize that "rules come first" is a fundamental principle, which differs from the "trial and error" approach of the common law systems in Europe and America. Therefore, if the functional positioning of stablecoins is not clearly studied, it may restrict their future development.

What exactly is the functional positioning of stablecoins? Zhang Jianhua pointed out that stablecoins are not legal tender, but they cannot simply be regarded as payment tools. Currency typically has five major functions: a measure of value, a medium of exchange, a store of value, a means of payment, and a world currency. Stablecoins can be exchanged for fiat currency at any time, reflecting their property as a store of value; some transactions are directly priced in stablecoins, demonstrating their function as a measure of value; while the circulation and payment functions of stablecoins are currently recognized as their main functions.

"Aside from not being issued by a central bank and lacking legal status, it actually possesses many attributes of currency," Zhang Jianhua pointed out, emphasizing that the "quasi-currency" nature of stablecoins determines that their regulation should be far stricter than that of ordinary investment products.

Zhang Jianhua noted that the advantages of stablecoins currently lie mainly in fast transaction settlement and low cross-border payment costs, which are based on the advantageous characteristics of blockchain. However, the application of stablecoins also comes with many challenges, such as conflicts between anti-money laundering, anonymity, and the transparency required by regulations.

Core Challenge: The Dual Game of Technology and Regulation

Stablecoins rely on blockchain technology, which brings efficiency improvements but also significant risks and regulatory challenges, especially issues related to anonymity that raise concerns about anti-money laundering, counter-terrorism financing, and transparency. In response to these challenges, Zhang Jianhua believes that efforts should be made from two aspects:

On the technical level, existing blockchain technology needs to achieve breakthroughs by "coding" regulatory requirements into it. He specifically mentioned the potential of smart contracts and programmable technology. If regulatory requirements can be embedded within the characteristics of smart contracts and other technologies, stablecoins might be shaped into a quasi-currency or a payment tool that meets regulatory requirements and can be approved for use, but the specific conditions still depend on whether effective management can be implemented through technical means.

On the regulatory level, given the inherent cross-border nature of stablecoins, international cooperation is crucial. The future development of stablecoins depends not only on whether technological advancements can meet regulatory requirements but also on regulatory tolerance and cross-border cooperation. This includes strict limitations on the qualifications of issuing entities, safety requirements for reserve management, and the depth of operational regulation, with the key being how much influence regulatory agencies can exert.

The regulatory policies of the issuer's location (which is usually also the country of the pegged fiat currency) are fundamental. Zhang Jianhua cited the recent passage of the "Guidance and Establishment of the U.S. Stablecoin National Innovation Act" in the U.S. as an example, emphasizing that strict access and ongoing regulation of issuing entities are core "levers." This act prioritizes the issuance of stablecoins by insured deposit institutions and their subsidiaries, while setting higher thresholds and stricter requirements for large technology companies and foreign institutions, such as strict compliance with consumer protection and anti-money laundering/counter-terrorism financing (AML/CFT) regulations. This direction indicates that regulation is more inclined towards stablecoins being issued by affiliates of traditional financial institutions.

"Grasp the issuing institutions and require them to comply with regulatory rules; if they cannot, they are not allowed to issue. This is the key to regulation," Zhang Jianhua pointed out that regulatory rules in places like Hong Kong also have similar restrictions on the qualifications of entities, with regulatory agencies ensuring compliance with various regulatory rules by controlling issuing institutions, and non-compliant entities will be prohibited from issuing.

Zhang Jianhua noted that international organizations are striving to introduce mature regulatory rules from traditional finance into crypto asset regulation. For example, the "Travel Rule" has been technically feasible, which requires that when financial transactions exceed a certain amount (e.g., $1,000/€1,000), the identity information of both parties must be transmitted along with the transaction so that regulatory agencies can track and prevent illegal activities.

Whether regulatory agencies in various countries can reach a consensus on key requirements (such as transparency standards, limited traceability, etc.) is a guarantee for the healthy development of stablecoins in the international environment. He mentioned that technically, it could be required that stablecoin systems maintain necessary transparency or traceability for regulatory authorities, judicial departments, and other institutions under specific conditions.

Application Scenarios: Cross-Border Payments and RWA Investments as Future Main Directions

Zhang Jianhua focused on analyzing the current and future main application scenarios of stablecoins and offered a cautious assessment of their advantages. He believes that the application scenarios of stablecoins need to be guided rather than left to run wild.

Currently, the most popular scenario for stablecoins is cross-border payments, with core advantages in low cost and fast speed. However, Zhang Jianhua pointed out that the actual costs of stablecoins may be underestimated. In addition to information transmission, subsequent transactions also involve a series of hidden costs, especially whether they still have a competitive advantage after regulatory constraints are imposed, which is the core issue determining whether this scenario can continue to thrive.

Considering the needs for trade settlement and capital flow, stablecoins as payment tools in trade and investment require the tokenization of real-world assets, namely RWA (Real World Asset tokenization). Zhang Jianhua views this as a key breakthrough to connect traditional finance with digital assets and broaden the application scenarios of stablecoins. If the tokenization of real-world assets is a future trend, this will be an excellent connection point. As the scale of on-chain financial assets related to RWA expands, the application scenarios of stablecoins as mediums of value exchange and payment tools will be greatly broadened. He specifically pointed out that such investment activities based on real assets are easier to trace in terms of fund flows and transaction backgrounds, which aligns with regulatory requirements.

Zhang Jianhua emphasized that cross-border payments and RWA investments are the main directions for the future development of stablecoins, with the latter potentially offering even greater opportunities than cross-border trade, as it truly bridges traditional finance and on-chain digital assets.

Strategic Considerations and Feasible Paths for RMB Stablecoin

Regarding the highly discussed issue of RMB stablecoins, Zhang Jianhua expressed a positive yet cautious attitude.

Referring to the practice of issuing HKD stablecoins in Hong Kong, Zhang Jianhua believes that mainland China needs to conduct in-depth research on its mechanisms and take substantial steps in exploring RMB stablecoins. He pointed out that currently, USD stablecoins (USDT, USDC) dominate the market, and if a HKD stablecoin pegged to the USD were to be launched, it would further consolidate the global influence of USD stablecoins.

The internationalization of the RMB certainly depends on multiple complex factors such as the depth of the domestic financial market and reforms. However, if China is absent in the field of stablecoins, the international monetary space for the RMB will undoubtedly be further compressed, and the usage rate and dominance of the USD will only increase. Therefore, issuing RMB stablecoins, especially in offshore markets, is an important measure to maintain the strategic space for RMB internationalization.

Regarding concerns that issuing RMB stablecoins may impact monetary policy, Zhang Jianhua believes a rational analysis is needed. From the current scale of USD stablecoins, their impact on U.S. monetary policy appears quite limited. Therefore, issuing stablecoins based on offshore RMB (CNH) in Hong Kong is also unlikely to have a significant direct impact on mainland monetary policy. The main potential challenge is that if offshore RMB stablecoins are allowed for cross-border flows, it may involve capital flow management issues, which require close attention and the design of corresponding mechanisms. Nevertheless, the pilot launch of HKD stablecoins in Hong Kong has already opened up a path worth exploring.

Zhang Jianhua also mentioned that mainland China needs to clarify the relationship between RMB stablecoins and digital RMB (e-CNY). The two are not mutually exclusive but can be parallel technological routes, just as Hong Kong is simultaneously advancing both digital HKD and HKD stablecoin projects and participating in the exploration of the multilateral central bank digital currency bridge (mBridge). The RMB system can fully draw on this approach, and even if it starts with small-scale pilots, its value is immense—helping us gain a deeper understanding of the actual operating mechanisms of stablecoins, their potential impacts, especially on payment and settlement systems, financial security and stability, and their interaction with monetary policy. Only through practical experience and data accumulation can we more scientifically assess the position of RMB stablecoins in national financial strategy and provide a solid foundation for future decision-making. This exploratory step holds forward-looking strategic significance for the RMB to secure a more favorable position in the international monetary landscape.

Zhang Jianhua concluded that the future development of stablecoins is the result of the interplay of multiple factors, including market innovation dynamics, technological problem-solving capabilities, effective regulatory frameworks (especially cross-border cooperation), and the expansion of application scenarios (particularly RWA). For the RMB system, actively and cautiously exploring stablecoins, especially offshore pilots, is of significant strategic importance and a necessary measure to address the challenges of the digital currency era and maintain monetary sovereignty and financial competitiveness.