2025-08-30
On December 30, 2024, the European Union's Crypto Asset Market Regulation Act (MiCA) officially came into effect, requiring stablecoin publishers to establish a 1:1 asset reserve and disclose transaction data in real time. At the same time, the US announced that it would include the confiscated 200,000 bitcoins in its strategic reserve, strengthening the "US dollar-crypto asset" cycle by supporting US dollar stablecoins. This regulatory difference is particularly significant in the compliance practice of Hong Kong HashKey Exchange : its KYT system accesses the 400 million address label library, intercepting 1,763 transactions involving sanctioned addresses such as Tornado Cash in 2024, with amounts exceeding 8.90 million US dollars. The cold wallet adopts a 2-of-3 multi-signature scheme, and the private key sharding is stored in the hardware security module (HSM) of Hong Kong, Singapore, and Switzerland, and requires authorization from both places to withdraw coins, achieving dual protection of asset security and compliance traceability.
MiCA divides crypto assets into payment-based (such as stablecoins), security-based (such as platform coins), and commodity-based (such as Bitcoin), implementing differentiated access standards. For example, important stablecoin publishers need to establish legal entities within the European Union, establish liquidity management mechanisms, and regularly conduct stress testing. This principle of "same business, same risk, same regulation" has made the European Union the first region to build a full-chain compliance framework, but it has also led to the comprehensive delisting of stablecoins such as USDT that do not meet the standards.
The SEC has recognized most tokens as securities through the Howey Test, requiring registration and disclosure of financial information; the CFTC treats Bitcoin and others as commodities and regulates their derivative trading. This disagreement led to Coinbase being fined $150 million in 2024 for violating two types of regulatory rules at the same time. In contrast, Hong Kong adopts a "license sandbox" model, HashKey Exchange through VATP license upgrades, formalized verification results of smart contracts are directly submitted to the Hong Kong Securities Supervision Commission. In 2024, 17 contract upgrades were completed through penetration regulation.
The European Union requires exchanges to access TRISA (Travel Rules Information Sharing Architecture) to exchange cross-border transaction data in real time; US FinCEN enforces "Know Your Transaction" (KYT), freezing illegal funds of more than $1.58 billion through on-chain analysis in 2024. HashKey Exchange 's KYT system, combined with 400 million address tag library, has an accuracy rate of 97% in identifying risky transactions, processing more than 42,000 compliance transactions in 2024, and reducing the risk of data leakage by 97%.
Chainlink's Automated Compliance Engine (ACE) enables cross-chain reuse of KYC credentials through the Cross-Chain Identity (CCID) framework. For example, a cross-chain lending protocol accesses European Union MiCA and US SEC rules through ACE, reducing compliance costs by 40% and shortening transaction confirmation time to 3 seconds. This technical solution has been included in the regulatory sandbox standard by the Hong Kong Monetary Authority and has become an industry model for cross-border compliance.
Binance invests more than $200 million a year in compliance, forming an FCC team including former FBI and European Union Agency for Law Enforcement Cooperation members to handle more than 63,000 enforcement requests in 2024. In contrast, Hong Kong allows companies to test innovative solutions in a controlled environment through sandbox mechanism, and HashKey Exchange 's hybrid storage model encrypts sensitive data chains, reducing data storage costs by 35% while meeting the GDPR right to be forgotten.
The European Union requires exchanges to have a minimum capital of 150,000 euros, while Hong Kong only requires 5 million Hong Kong dollars (about 640,000 US dollars). This difference has led to 12 European exchanges relocating to Hong Kong in 2024, and their trading volume proportion has increased from 18% to 32%. However, regional differences in compliance costs also bring hidden dangers: a stablecoin project was forced to stop operating due to compliance in the European Union but violation in South Korea.
The essence of cryptocurrency regulation is a dynamic game between technological innovation and social governance. From the risk classification of the European Union MiCA to the strategic reserve of the US, from the on-chain monitoring of the HashKey Exchange to the cross-chain compliance of Chainlink, the industry is experiencing the pain of "wild growth" to "rule reconstruction". Users need to be vigilant: platforms that are not connected to the KYT system may have blind spots in asset traceability due to compliance vulnerabilities.