Both the U.S. and China share an interest in preventing illicit finance, strengthening cybersecurity and ensuring global stability. What happens next will depend less on technology than on values and governance.
In 2025, the U.S. Congress took a decisive step in shaping the regulatory landscape for digital assets. In July, the House of Representatives advanced three major pieces of legislation: the Guiding and Empowering National Innovation for U.S. Stablecoins Act (GENIUS Act), the Digital Asset Market Clarity Act of 2025 (CLARITY Act, H.R.3633), and the Anti-CBDC Surveillance State Act (H.R.1919). The GENIUS Act was signed into law by President Donald Trump on July 18; the CLARITY Act and Anti-CBDC Act have passed the House and are pending Senate review.
Three laws, three domains
The GENIUS Act is centered on stablecoins. It establishes a dual federal-state regulatory structure requiring issuers to hold high-quality reserves, maintain capital adequacy standards and disclose reserve compositions regularly. This framework places stablecoins closer to the regulatory standards of banking and money market funds while also giving states room to license smaller issuers. The CLARITY Act addresses the core issue of asset classification. Meanwhile, the Anti-CBDC Act explicitly prohibits the Federal Reserve from issuing a central bank digital currency that is deemed to enable U.S. government surveillance, reflecting Republican distrust of centralized state power.
The separation of these issues into three bills reflects both legal necessity and political strategy. Stablecoins, asset classification and CBDCs involve different statutory regimes, regulatory agencies and ideologies. Bundling them into a single bill would have complicated passage, while dividing them ensures targeted consensus-building. Still, it must be noted that these three laws, while comprehensive, do not exhaust the digital asset regulatory agenda. They leave open questions such as anti-money laundering obligations for decentralized finance, taxation of crypto transactions and custody rules for banks and brokers/dealers.
Globally, the U.S. framework will reverberate strongly. First, legalizing and regulating stablecoins may cement the dominance of digital dollars in international finance in the short to medium term. Chainalysis estimated that stablecoin transfers totaled $3 trillion in 2024, with more than 80 percent denominated in dollars. Legal clarity would likely accelerate their adoption for retail payments, corporate treasuries and cross-border remittances. Second, by clarifying market categories, the U.S. could pull business away from competing jurisdictions. Europe’s MiCA regulation, while comprehensive, is viewed as restrictive, especially for DeFi and algorithmic stablecoins, potentially driving firms back to U.S. markets. Third, by rejecting CBDCs, the U.S. frames the global competition over digital money not as a technological race but as a battle of governance models — privacy and free markets versus so called state-driven financial architectures.
Implications for China
For China, U.S. legislation brings challenges but also opportunities. On one hand, dollar-backed stablecoins could strengthen the role of the U.S. dollar in global payments, complicating China’s strategy of promoting internationalization of the yuan and the digital RMB (e-CNY) in countries participating in the Belt and Road Initiative.
On the other hand, the America’s rejection of CBDCs leaves China as the uncontested leader among major economies experimenting with sovereign digital currencies. By mid-2025, the e-CNY had already been tested in more than 20 pilot cities and used in limited cross-border trials with Hong Kong and the UAE under the mBridge project.
Rather than diminishing China’s prospects, U.S. legislation may accelerate them. First, The U.S. retrenchment in the field of CBDCs has created greater space for China to shape technical and governance standards on multilateral platforms such as the Bank for International Settlements and in the BRICS bloc. Second, U.S. regulatory clarity may attract some private firms, but it also consolidates China’s comparative advantage in its financial infrastructure, reinforcing China’s potential to promote the e-CNY as a trusted alternative for governments wary of U.S.-centric finance. Third, the symbolic framing — with the U.S. as the market-driven model and China as the sovereign-led model — could allow China to align with countries in the Global South that prioritize monetary sovereignty over integration with Western private finance.
Strategic responses for China
China has noticed the shifts in the international monetary system and the forthcoming transformations. In this context, Pan Gongsheng, governor of the People's Bank of China, stated in his keynote speech at the 2025 Lujiazui Forum in June, that “historically, the international monetary system has always been evolving. … Technologies such as blockchain and distributed ledger systems are driving the rapid development of central bank digital currencies and stablecoins.”
Actually, progress is evident in China. In terms of yuan internationalization, on Sept. 24, Shanghai launched the International e-CNY Operations Center, which is building platforms for cross-border payments, digital assets and blockchain-based services.
In terms of blockchain applications in capital markets, progress has also reached the practical stage. In October 2023, the China Securities Regulatory Commission released a consultation draft of the Guidelines on the Regulation of Regional Equity Markets No.2-Blockchain Development, setting unified requirements for the construction and operational security of blockchain systems in regional equity markets. Before this, the Shenzhen Stock Exchange’s financial blockchain platform had supported the rollout of depository and custody systems in regional equity markets such as Beijing and Guangdong, enabling full-process on-chain management of business data.
In addition, Hong Kong’s differentiated approach has created a valuable testing ground for the development of virtual assets in China. Since June 2023, HK has implemented a licensing regime for virtual asset trading platforms that allows licensed institutions to operate legally in the city. In response to the evolving international financial landscape, the Hong Kong Securities and Futures Commission has continued to refine its regulatory framework to strike a balance between encouraging innovation and mitigating potential risks. For example, in August the SFC issued a circular requiring licensed platforms to comprehensively upgrade client asset custody standards to safeguard investor interests and promote the stable development of the market.
Together, these initiatives demonstrate that China is not merely reacting to U.S. legislation but proactively positioning itself to be in line with technological trends and the evolving landscape of international finance, while also aligning with its own development needs.
A shared future
Looking ahead, two parallel systems might emerge. On one side, U.S. stablecoins dominate digital commerce, extending dollar power through private issuers. On the other, China’s e-CNY system expands, offering an alternative for states seeking more sovereignty over their own monetary affairs.
These two paths are not destined for confrontation. Both the U.S. and China share an interest in preventing illicit finance, strengthening cybersecurity and ensuring global stability. What happens next will depend less on technology than on values and governance. If the U.S. and China can pursue a balance of competition and cooperation, the world may end up with a digital financial order that is not only more dynamic but also more resilient and inclusive.
