Stablecoin Development Pathways: A Comparative Analysis of Regulatory Logic and Market Landscape in China and the United States
Main Article Content
Keywords
stablecoins, regulatory logic, market landscape, central bank digital currency, cross-country comparison
Abstract
The global stablecoin market has reached roughly $280 billion, with dollar-pegged instruments accounting for over 92% of circulating supply. Existing scholarship largely treats the United States and China separately, leaving the regulatory logic and market structure of the two systems uncompared. This paper adopts a two-dimensional comparative framework—regulatory logic and market landscape—to examine why the two economies have taken opposite stablecoin paths. Using comparative case-study evidence and an event-study test of two policy shocks, it finds that the United States built a compliant private-issuance model under the GENIUS Act to extend dollar usage in digital payments, while China banned private stablecoins and promoted the central bank digital currency e-CNY to defend monetary sovereignty and financial stability. An event study shows that China's September 2021 ban induced a post-event cumulative abnormal return (CAR(+1,+30)) of RMB-pegged stablecoin proxies of -93.5%, while the U.S. Senate's passage of the GENIUS Act in June 2025 induced a full-window cumulative abnormal return (CAR(-30,+30)) of +9.4% for dollar stablecoins, both significant at the 1% level. The divergence is explained by differences in monetary institutions, regulatory philosophy, capital-account regimes, and engagement with international governance bodies. The framework offers a reference for digital-asset governance in other economies.
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