RWA Window in Asia: The Policy Gate of Vietnam and the Standardization Race in Hong Kong

The sea breeze rises from the South Seas, and the sound of the tide surges towards Victoria Harbour. Almost in the same week, Vietnam and Hong Kong coincidentally reached into the gearbox of Real World Assets (RWA): Hanoi introduced legislation and permits aimed at rapid ignition; Hong Kong, on the other hand, set down regulatory 'guidelines,' officially enacting the Stablecoin Regulation on August 1, tying stablecoins to the keel of financial infrastructure. The two paths are like race cars at the starting gun: one uses law as a dam to channel the flow; the other uses regulation as a ruler to calibrate direction. Who is faster, who is steadier, is determined not only by the convenience of the issuance channel and the depth of capital acceptance but also by the future 'pricing power' of assets and the weight of discourse. For the industry, this is a dual test of the system: can speed be maintained without losing control, and can stability be achieved without losing momentum.

"Gate" and "Scale": Two Institutional Approaches to Opening

Vietnam's actions are characterized by a typical national engineering style, and its regulation of digital assets is undergoing a fundamental transformation from ambiguity to clarity. In early August 2025, the National Assembly of Vietnam passed the "Law on Digital Technology Industry," which officially categorizes digital assets into two types: "virtual assets" and "cryptographic assets," and recognizes cryptographic assets as legitimate property rights under civil law. This legislation is expected to take effect on January 1, 2026, marking a milestone step for the country in the field of cryptography. The new law aims to improve the related legal framework, align with international regulatory standards, and help Vietnam exit the Financial Action Task Force (FATF) gray list as soon as possible, necessitating the enforcement of anti-money laundering (AML) and counter-terrorism financing (CTF) measures. At the same time, it sets clear boundaries for tokenized bonds, real estate, and other real-world assets (RWA), and authorizes the State Bank of Vietnam (SBV) to work with securities regulatory authorities to approve the first batch of digital asset exchanges in subsequent cycles, using an embedded sandbox for phased validation.

Vietnam's regulatory system is currently divided among multiple ministries, forming a pattern of "loose regulation." This includes: the State Bank of Vietnam (SBV) as the most conservative and prudent institution, focusing on maintaining financial stability and exploring the central bank digital currency (CBDC) pilot; the Ministry of Finance (MoF) leading the formulation of laws and regulations regarding digital assets and the improvement of the tax framework; the Ministry of Justice (MoJ) promoting the clear definition of digital assets as a new asset class to address ownership disputes and uncertainties in legal contracts; and the Ministry of Public Security (MoPS) combating financial crime and proposing stricter "know your customer" (KYC) and suspicious transaction report (STR) protocols for cryptocurrency platforms. In addition, the Vietnam Blockchain Association (VBA) acts as a bridge connecting the government and the industry, promoting the application of blockchain technology solutions in various aspects of economic life. The country is also actively introducing regulatory sandbox mechanisms and pilot projects, such as testing the use of the stablecoin USDT for international tourists in Da Nang, to explore innovative applications under controllable risk.

The path is clear: first solidify the legal framework, then gather resources through "licensing + pilot" to quickly form a compliant entry and liquidity hub. This top-down design has the advantages of strong execution, short pathways, and strong signals, but the cost is a higher dependency on approvals and single-point platforms, and the flexibility and space for market corrections need time to develop.

In contrast, the main theme of this round in Hong Kong is not to "set up another exchange," but to bring stablecoins onto the financial "right track," first solidifying and stabilizing the most basic clearing and pricing "monetization tools." On August 1, the "Stablecoin Regulation" officially came into effect, marking the global first comprehensive regulatory framework specifically targeting fiat stablecoins entering the operational phase. The regulation constructs a regulatory base with a "three-pillar" structure: the licensing system locks in access thresholds and ongoing compliance; reserve regulatory requirements mandate 100% coverage with high-quality, highly liquid assets and independent audits; and redemption guarantees require payment at face value within a reasonable timeframe and real-time reserve monitoring. The regulatory reach extends to extraterritorial effects and advertising restrictions, setting up an adjudication mechanism to form a closed loop from access, operation, information disclosure to remedy. The Monetary Authority and the Securities and Futures Commission subsequently spoke jointly, emphasizing the principles of prudence, stability, and a cautious advance, clearly indicating the market's vigilance against "rumors-speculation-volatility," linking the "financial functions" of stablecoins with "market order."

If Vietnam is building a "high-speed channel," prioritizing putting cars on the road and letting them run first; Hong Kong is establishing a complete set of "traffic rules," calibrating vehicle conditions and fuel before allowing test runs, ensuring that the road network can bear the load and that vehicles can be interconnected. Vietnam takes the lead in the "centralization" of entry, while Hong Kong shapes the "extensibility" of rules. The two are not in conflict: the former leads in speed, while the latter accumulates strength in stability and sustainability. For the RWA industry, who is more suitable is not about a dispute of ideas, but about what your business "wants" and "how long" it will take.

Regulatory explorations in other Southeast Asian countries

As a pioneer in this field, Singapore's Monetary Authority of Singapore (MAS) actively promotes and regulates tokenized securities through its "FinTech Regulatory Sandbox." MAS does not support cryptocurrencies for retail use but actively implements institutional stablecoin initiatives and studies the viability of tokenizing real-world assets (RWA) through "Project Guardian," aiming to reduce financing barriers and increase liquidity in financial markets. The country enforces a strict licensing regime for virtual asset service providers (VASP) and digital payment tokens (DPT), requiring that stablecoin reserve assets must be low-risk and high-liquidity assets, and must always equal or exceed the value of stablecoins in circulation. Singapore, with its efficient regulatory mechanism, leads many countries in formulating and enforcing complex regulations.

Malaysia adopts a dual regulatory model, with the Securities Commission (SC) responsible for regulating digital payment tokens and digital asset exchanges, while the central bank (BNM) oversees fiat-pegged digital currencies (stablecoins). The SC takes an open attitude towards asset tokenization projects, believing they contribute to financial inclusion, asset circulation, and improved transaction efficiency, but emphasizes that even if the underlying assets are legally stable, the tokenization itself must still fulfill securities regulatory obligations. The country has institutionalized, monitored, and made accountable the token issuance system through the IEO (Initial Exchange Offering) framework, resulting in compliant cases such as fixed-income tokens from Integra Healthcare (with annual returns of 7.8%–10%) and tokens from the BidNow platform (attracting nearly 500 investors and raising over 10 million ringgit). The SC has also released consultation documents, clearly stating that in the future, even traditional capital market products such as stocks, bonds, and funds tokenized through distributed ledger technology (DLT) should still be treated as traditional securities.

The regulation of cryptocurrency in Thailand is mainly overseen by the Securities and Exchange Commission (SEC) and the Ministry of Finance. Businesses must obtain a license to engage in cryptocurrency activities, such as trading platforms, and the application process typically takes 6 to 12 months. The country requires cryptocurrency companies to have at least one director who is a resident of Thailand, and all directors must have experience in finance or technology and pass background checks, as well as have a physical office address in Thailand and establish anti-money laundering (AML) and know your customer (KYC) policies. In 2021, an institution in Thailand issued 240 million tokens for a portion of an office building in Bangkok, totaling 70 million USD.

Indonesia has the second largest number of fintech companies in Southeast Asia (after Singapore), and its Financial Services Authority (OJK) and Central Bank (BI) support the development of fintech through various regulations, and have established a regulatory sandbox mechanism for testing new models.

The regulation of Digital Payment Tokens (DPT) in the Philippines is jointly overseen by the Securities and Exchange Commission (SEC) and the Bangko Sentral ng Pilipinas (BSP). Virtual Asset Service Providers (VASP) are required to register with the BSP and obtain a license from the SEC, while also needing to separate customer funds from company assets and regularly submit reports on transactions, balances, and operational data.

The fast-running channel, the slowly-ground seal: the dual choice of the issuer

From the issuer's perspective, institutional differences first manifest in the "entry methods" and "landing efficiency." The most notable feature of the Vietnam model is that exchanges become the main entry point for compliant flows and clearing. Obtaining a license and going live on designated platforms is equivalent to accessing local capital pools and policy dividends. For example, the Vietnamese government has discussed establishing regional and international financial centers and plans to set up a fintech regulatory sandbox within them, allowing for testing of crypto assets and cryptocurrency business models, with trading potentially starting as early as July 1, 2026. The process is short and fast-paced, especially suitable for the "early landing" of asset categories such as bonds, real estate, and supply chain receivables. Marginal restrictions are equally clear: issuers need to have psychological expectations regarding platform operational capabilities, administrative approval timelines, and the subsequent expansion pace of incremental asset categories. In simple terms, this is a resonance between rapid financing and policy certainty, suitable for projects prioritizing scale and speed.

The logic in Hong Kong is different, as it is driven by the goal of stabilizing foundational currency tools like stablecoins, providing RWA issuance and settlement with a "trustworthy anchor for underlying clearing and pricing." On August 1, 2025, the "Stablecoin Regulation" will officially take effect, marking the world's first comprehensive regulatory framework specifically targeting fiat stablecoins entering the operational phase. The regulation constructs a regulatory foundation based on a "three-pillar" structure: a licensing system that locks in entry thresholds and ongoing compliance, reserve regulatory requirements that ensure 100% coverage with high-quality, highly liquid assets and independent audits, and redemption guarantees that require payment at face value within a reasonable timeframe and establish real-time reserve monitoring. The regulatory touch extends to extraterritorial effectiveness and advertising restrictions, and an arbitration mechanism is set up to create a closed loop from entry, operation, information disclosure to relief.

Specifically: First, the entry threshold is 'financial-grade'. The applicant must be a Hong Kong company or an approved institution with a registered office in Hong Kong, with a paid-in capital of no less than HKD 25 million. The regulatory authorities are very strict about this, paying high attention to the applicant's background in financial risk control, anti-money laundering experience, and capability, emphasizing that only a few licenses will be approved in the initial licensing phase. Second, the credibility of funds and operational availability significantly increase. Reserve assets must be fully covered by high-quality, highly liquid assets (such as cash and short-term government bonds) and independently custodied by licensed banks. The Hong Kong Monetary Authority (HKMA) holds an open attitude towards the issuance of HKD stablecoins in Hong Kong, allowing their reserve assets to be denominated in USD, and accepting tokenized forms of cash, bank deposits, and securities guaranteed by the government or qualified international organizations. This hard constraint aims to ensure that issuers are truly 'responsible for one coin, one anchor'. Third, there are mandatory KYC real-name systems and strict anti-money laundering (AML) and counter-terrorism financing (CTF) requirements. Stablecoin issuers must not only verify user identities and retain real-name data for at least five years but also must not provide services to anonymous users, and even have an identity verification obligation for every stablecoin holder at the initial stage. This is aimed at ensuring that regulated stablecoins issued in Hong Kong achieve mainstream application based on a balance between risk control and sustainable business development. The regulations also clarify extraterritorial effect; even if issued outside Hong Kong, as long as it refers to HKD or actively faces the public in Hong Kong, it falls under the regulatory purview and prohibits unauthorized advertising and misleading statements, with violations facing heavy fines and criminal penalties. Additionally, issuers are not allowed to pay interest to stablecoin users but may provide promotional offers.

On the business side, the issuer's "calculations" will become more precise:

If your goal is to quickly launch, connect with local funding, and achieve initial volume, Vietnam's "license-registration-sandbox" is an efficient pathway. If your goal is to gain long-term trust from institutional funds, expand cross-border payments, supply chain finance, and RWA settlement with stablecoin as the foundation, Hong Kong's "licensing-reserve-redeem-prudent regulation" resembles a ticket to access large capital pools and international recognition.

It is worth noting that the Hong Kong Monetary Authority's "Ensemble Plan" has announced several tokenization-themed case studies, including a financial technology company that facilitates token issuance through the construction of a "two chains and one bridge" platform, introducing overseas financing for RWA projects related to green energy assets in mainland China, with the largest financing scale reaching 200 million yuan. For example, Ant Group collaborated with Longxin Group to split the revenue rights of 9,000 charging piles into 100 million yuan tokens, completing Hong Kong's first new energy asset RWA project. In December of the same year, Ant Group also completed a 200 million yuan RWA financing for Xiexin Energy Technology. These cases demonstrate how RWA, through blockchain technology, tokenizes the revenue rights of physical assets, achieving asset segmentation, public ledgers, free circulation, and automated management. The key aspect is the application scenarios.

Stablecoins are not "speculative coins" for RWAs, but rather the payment and settlement engine that connects RWAs to the real economy. According to industry statistics, by May 2025, the global market value of stablecoins will exceed $250 billion, with an annual trading volume exceeding $20 trillion, making cross-border payments, supply chain finance, and digital asset settlements mainstream scenarios. Connecting this engine to a compliant power source means three "real" gains for issuers: faster cross-border arrival, lower capital friction, and clearer audit trails. You can think of the Hong Kong dollar stablecoin as a "low-loss fiber optic" that connects the RWA issuance side to the global funding side; it does not create traffic but can reduce attenuation over long-distance transmission.

Moat and Microscope: Two Types of Security in the Eyes of Investors

On the Vietnam side, policy endorsement and exchange licenses bring a sense of "national credit" security, especially in the early market education stage. Investors can participate in tokenized bonds, real estate, and other assets through compliant platforms, with clear pathways and controllable counterparty risks. The new legislation explicitly recognizes crypto assets as legal property rights under civil law, providing a solid foundation for individuals and businesses to legally hold and trade crypto assets. However, shortcomings are also evident: information disclosure is still in the improvement phase, and the cross-border recovery mechanism is still in the adjustment phase. In the event of cross-border defaults or liquidity tightness, whether and how to "quickly, fully, and across borders" handle these situations remains to be refined through both institutional and practical approaches. Vietnam faces challenges in developing blockchain technology and digital currency governance, including a lack of experts, limited understanding of technology, and inadequate infrastructure. This makes transparency and verifiability key concerns for global institutional funds.

On the Hong Kong side, the regulatory design incorporates "transparency" and "exit" into the system's fabric. Firstly, there is a systematic improvement in information transparency. The full chain requirements of licensing, reserves, audits, and redemptions enable investors to continuously see the composition of reserve assets, redemption arrangements, and technical security. The Hong Kong Monetary Authority (HKMA) requires licensed stablecoin issuers to have their reserve asset status verified monthly by independent auditors to build public confidence. Unauthorized advertising and inducement are expressly prohibited, and fraud and misleading practices face fines of up to ten million HKD and long-term imprisonment, raising the cost of "deceptive marketing" to a "criminal level." At the same time, the Securities and Futures Commission (SFC) of Hong Kong has released guidelines on the issuance of security tokens and is formulating a regulatory framework for virtual assets, including tokenized securities. Secondly, there is predictability in the exit path.

Redemption guarantee requirements state that under normal circumstances, the issuer must fulfill redemption requests within one business day of receiving them, and should fulfill the redemption requests at face value in one or more currencies referenced, without unreasonable fees or conditions. In the event of operational disruptions or financial stress, licensees must proactively report such issues, and regulators may intervene for investigations, appoint advisors, or statutory managers to provide law enforcement measures for payment and settlement. Thirdly, there is a counter-cyclical constraint on "emotional fluctuations." Recently, the Monetary Authority and the Securities Commission jointly issued a statement explicitly naming the rumors and speculation surrounding stablecoins in the market, reminding the public to treat various statements of "intended application," "in communication," and "in exploration" with caution, and emphasizing that only a few licenses will be granted initially, with significantly high thresholds, and that progress will be made in a steady and orderly manner. Regulators clearly convey the message: do not treat the "wind" on social media as regulatory conclusions, and do not regard short-term stock price fluctuations as proof of long-term value. For investors, this timely "cooling down" and process transparency itself is a form of protection.

Beyond the Maze: Questions of Cross-Border and Collaboration

Whether choosing Vietnam or Hong Kong, the scaling of RWA cannot avoid four structural issues.

Firstly, cross-border recognition. Without recognition, even the most attractive system is just "local circulation." Whether Vietnam's licenses and products can gain acceptance from surrounding markets and offshore capital policies; whether Hong Kong's licensed stablecoins and their disclosure standards can be regarded as "effective benchmarks" by Southeast Asian funds and European and American institutions determines whether the products can enter a truly global portfolio. This is not something that can be solved by the efforts of a single institution; it requires bilateral/multilateral regulatory alignment and compatibility with industry standards.

Second, tax treatment. Tokenized assets often accompany cross-border cash flows. Vietnam has begun to gradually improve its tax framework, possibly testing a 0.1% transaction tax, a 20% corporate income tax, and even setting a separate tax rate of 5-10% on NFT profits, while providing tax incentives for compliant exchanges. How Hong Kong will define the capital gains and deduction principles related to stablecoin transactions. Tax uncertainties not only alter net yield but may also create "invisible barriers" on the compliance side. For issuers and investors, tax pre-planning and jurisdiction selection are necessary actions before implementation.

Thirdly, data and privacy. RWA is inseparable from continuous disclosure, but the underlying data often touches on corporate financial reports, personal credit information, and supply chain transaction details. Vietnam is relatively cautious about cross-border data flow, and Hong Kong also needs to make trade-offs between transparency and privacy. For financial institutions, "minimum necessary disclosure" + cryptographic tools that are "verifiable and leave no trace" may become part of the technical solutions; for regulators, how to draw a dynamic boundary between promoting transparency and protecting sensitive information determines the industry's "sustainable disclosure capability."

Fourth, law enforcement cooperation. Once there is a cross-border default or mismanagement, how to determine jurisdiction, how to collect evidence, and how to advance recovery are the "ultimate tests" for RWA's long journey. Under the framework of "national leadership + platform entry," Vietnam needs to establish a regular case cooperation with foreign regulators; Hong Kong grants the Monetary Authority investigation powers, sanctioning powers, tools to designate entities, designate advisors/ statutory managers, etc., and sets up a stablecoin adjudication office, providing procedural relief channels. However, cross-border enforcement still needs to align with other legal jurisdictions to avoid falling into the dilemma of "each acting on its own, insufficient cooperation."

Beyond these common challenges, the "stablecoin regulation" itself also delineates several "hard boundaries" that must be respected. In terms of definition, the regulation clearly states that stablecoins are digital value representations based on distributed ledger technology, used by the public as a medium for payment, settlement, or investment, and claim to maintain stability by referencing a single asset or a basket of assets; central bank digital currencies, traditional securities, or futures contracts are excluded. The scope of activities covers not only stablecoins issued in Hong Kong but also those issued outside Hong Kong that reference the Hong Kong dollar or are actively aimed at the Hong Kong public. The licensing system requires financial soundness, complete governance, adequate reserves, technological security, and clear investor protection mechanisms, and sets high penalties and criminal liabilities for providing retail services without permission, misleading and fraudulent activities, and advertising. Transitional arrangements allow for an orderly switch during the initial period of effectiveness, and the tribunal ensures procedural justice in applications and sanctions. These provisions together form a governance framework that states "innovation is allowed, but the boundaries must be clearer."

Bringing the perspective closer to the industry: compliant stablecoins are not everything about RWA, but they are almost a "must-have option" to truly connect RWA to the real economy. The minute-level cross-border payment arrival, significant reduction in fees, and the tokenization and traceability of supply chain finance will all become trustworthy and usable under a stablecoin system that has licenses, reserves, and redemption guarantees. Industry research predicts that by 2030, supply chain finance driven by compliant stablecoins is expected to exceed a trillion-dollar scale. The exploration of interconnectivity between digital RMB and HKD stablecoin in Hong Kong and mainland China, along with Vietnam's accelerated attempts in trade and investment digitization, will extend this "expressway" to more factories, more docks, and more ledgers.

Conclusion

The system is like a riverbed, and capital flows like water. The "system competition" between Vietnam and Hong Kong appears to be a race for speed, but at a deeper level, it is a competition for who can direct the water in a longer, steadier, and clearer manner. Vietnam has built a "fast track" through legislation and licensing, providing the market with a key that can be quickly turned; Hong Kong, through regulations and licensing, solidifies "hard constraints," refining the stablecoin engine to a financial grade, and then allows it to drive cross-border payments, supply chain finance, and RWA settlement.

For issuers, this is a choice between "fast financing" and "strong endorsement"; for investors, it is a trade-off between "policy guarantees" and "market transparency." The "channel strategy" of RWA does not have an absolute optimal solution, but it determines who is more likely to gain pricing power in the future: it is not the market that shouts the loudest, but the institutional designer that can balance speed and stability, and bridge and pave the way between mutual recognition and collaboration. As for the finish line? It is never about who arrives first, but about who can run more steadily and further, while also bringing more ships into the sea.

Author: Liang Yu Zhao Qirui

Editor: Zhao Yidan