Navigating the Compliance and Innovation Narrow Gate: Five Key Highlights of HashKey's Listing

December 17, 2025, HashKey (3887.HK) successfully listed on the Hong Kong Stock Exchange. HashKey’s IPO marks a crossroads in history. On one hand, the United States is vigorously advancing crypto economy compliance, Wall Street is gearing up, and the trillion-dollar RWA industry is ready to surge. On the other hand, at the end of November, the People’s Bank of China, together with thirteen departments, reaffirmed its stance to crack down on virtual currency trading and speculation. At this contradictory moment, HashKey’s listing has triggered a wave of emotional interpretations within the industry. Whether positive or negative, everyone agrees that this event is not just a company’s bell-ringing moment, but also a key indicator event signaling Asia’s crypto asset industry moving towards “legitimacy.” HashKey has thus become an extremely rare observational sample in the Asian crypto narrative.

Just now, I saw a letter from Dr. Xiao addressed to all HashKey employees, in which he said: “This is the hardest path, and we have walked it together correctly.” Reading this, I feel quite emotional. I have known HashKey founder Dr. Xiao Feng for many years; he is a senior and innovator in the financial industry and a thought leader in the global blockchain space. We share many common ideas and values, and in many aspects, he has been my teacher. Over the years, I have been paying close attention to HashKey’s development, fully aware of Dr. Xiao’s perseverance and difficulty in over a decade of dedication to Wanxiang Blockchain. Today, finally achieving a phased success, I sincerely feel happy for Dr. Xiao and all HashKey friends.

However, this is not a PR soft article, nor do I intend to add a congratulatory note. I prefer to provide a cool and cautious perspective at this moment. Recently, HashKey’s prospectus was released, and there have been many interpretations and discussions. The data is honest: while revenue has experienced explosive growth, it is also accompanied by losses due to high compliance costs and R&D investments. Many are asking: HashKey bears the high costs of compliance, raises the banner of long-termism, but what is it ultimately aiming for? Will its prospects be bright?

This is indeed an important question, not only concerning HashKey itself but also the overall route of Asia’s crypto industry. I want to analyze the deep logic and challenges behind HashKey’s listing from five dimensions.

1. Asset-side Reconstruction—Can HashKey bring quality RWA assets onto the chain?

Currently, the biggest narrative in the entire crypto industry is RWA. After the US market structure law passes in the first quarter of next year, trillions of dollars of RWA assets will be rapidly moved onto the chain. This means that in the second half of next year, or at the latest by 2027, you will be able to use stablecoins to invest in US stocks, US bonds, and various financial assets on-chain. SEC Chairman Gary Gensler repeatedly emphasizes that the significance of this is comparable to the birth of paper securities and the digitization of securities—a revolutionary event akin to the “movable type printing” in human financial history. Yet, not only the public, even many financial professionals seem numb to this. Mainland China has just clarified its stance, deciding to strictly guard against this trend and not give an inch. How long can they delay? Outside China, Asia still has a huge asset scale, with hundreds of billions of dollars in funds and countless talented entrepreneurs. Facing the imminent RWA wave, Asia needs a response.

Looking across Asia, the only one taking a compliant stance to positively respond to the RWA challenge is HashKey.

What will HashKey do?

One approach, which is actually the simplest and safest—becoming a compliant distribution channel for US RWA assets entering Asia.

Under this model, HashKey’s main task is to bring RWA products, already structured, legally qualified, and risk-priced in the US, into the Asian market within a compliant framework, providing trading, custody, and settlement services. US stocks, US bonds, ETFs, and even more complex structured products can circulate on-chain in token or coin form.

The advantages of this path are obvious: clear asset quality, mature regulatory logic, ready-made pricing systems. HashKey mainly acts as an “onshore compliant gateway,” with high business model certainty and relatively controllable execution risks. HashKey leverages Hong Kong’s unique geographical advantage. The prospectus discloses a key detail: HashKey has established cooperation with 39 traditional brokerages through Omnibus accounts. This means that millions of traditional Hong Kong stock accounts could theoretically seamlessly access crypto assets. It’s a clever B2B2C approach, directly leveraging traditional financial traffic channels.

But the problem is equally clear—this is a low-risk, low-ceiling path.

In this mode, Asia only technically connects to US financial assets but does not participate in shaping the core paradigm shift of RWA assets. The defining rights, rule-making authority, and financial narrative power still remain firmly in Wall Street and the US regulatory system. HashKey ultimately resembles a compliant “channel provider,” not a builder of RWA infrastructure.

We also have to consider a question: under the current US-China geopolitical game, how tolerant is the Hong Kong regulator of US assets? How high is the business ceiling?

Another approach is much more difficult and closer to true “asset-side reconstruction”—drawing on Wall Street’s experience, to foster a batch of local Asian RWA assets, completing the full cycle of compliant on-chain structuring, pricing, and trading.

This means HashKey would not just introduce existing assets but deeply participate in asset screening, structuring, disclosure, compliance interfacing, and secondary market liquidity cultivation. In other words, it’s not about “selling others’ RWA,” but helping Asian assets become RWA.

This path faces enormous challenges.

First, there is no clear legislation or regulatory framework. Second, local Asian assets generally lag behind US assets in transparency, standardization, legal enforceability, and cross-border regulatory coordination. At the same time, this model entails higher compliance costs, longer cultivation cycles, and early-stage inevitable low liquidity and high uncertainty. From a short-term financial return perspective, this is not a “listings-friendly” path.

But from a longer-term perspective, this is precisely the critical watershed that will determine whether HashKey can upgrade from a “compliant trading platform” to “Asia’s RWA infrastructure.”

If Asia always lacks a voice in the asset side during the RWA era, then no matter how prosperous on-chain trading becomes, it will ultimately only be a marketplace for US assets. Conversely, if a replicable, auditable, scalable Asian local RWA on-chain paradigm can be established step by step, HashKey’s role will no longer be just following the trend but actively shaping it.

Of course, reality may not be a binary choice.

HashKey is very likely to pursue both paths simultaneously for a considerable period: one side scaling through US RWA assets, the other tentatively experimenting with compliant on-chain Asian assets on a smaller scale. But it must be acknowledged that what truly determines its long-term industry position is not which path is faster, but which path is further.

RWA is a revolution on the asset side, not just product innovation.

Whether HashKey can play a role beyond “channel” in this revolution is the most worth ongoing observation after this listing.

2. Asset selection rights—Can HashKey incubate a batch of sustainable high-quality projects?

Almost all exchanges have talked about “ecosystem building,” but the historical results have not been ideal.

The reason is simple: the incentive mechanism of exchanges is inherently biased toward short-term liquidity rather than long-term project success.

HashKey’s difference lies in bearing stronger compliance and disclosure pressures, which theoretically suppress “quick pump-and-dump incubation.” But the question is: in a highly compliant environment, can truly network-effect and organically growing Web3 projects still be nurtured?

If only low-volatility, low-narrative, low-risk projects are incubated, the ecosystem might be safer but also more mediocre. This is a structural tension all “compliant exchanges” face.

In offshore markets, exchanges are often both referees and players, with token listing logic full of利益输送和短期炒作. Since HashKey has chosen the onshore (Onshore) compliant route, it is destined not to follow this old path.

HashKey has a unique “full-ecosystem closed loop”: from primary market VC investments, to secondary market asset management, to liquidity support from the exchange. This architecture grants it strong asset screening and pricing capabilities. But I am more concerned whether it has the courage to say “No” to inferior assets.

In Dr. Xiao Feng’s letter, he mentions the need “to set a true long-term example for the entire industry.” This means HashKey must maintain strategic focus in a market full of high volatility and high multiples, incubate and support projects with real technological implementation and complete business cycles. This requires not only vision but also the resilience to resist short-term profit temptations. For investors, whether HashKey can become Asia’s “asset filter” is a key indicator of its core competitiveness.

3. Value distribution experiment—Can HashKey explore a new tokenomics model?

Many may not realize that HashKey’s listing created a world first: it is the first company in the world to issue its own token ($HSK) and be listed on a mainstream capital market simultaneously. This means HashKey is traded both in the stock market and in the crypto market: HashKey Group is a listed company (3887.HK), representing shareholder interests, seeking profits and dividends; while its underlying ecosystem HashKey Chain and platform token HSK represent community and ecosystem interests.

This brings a highly experimental point—how does a listed company operate a token economy at the same time? In Web2, shareholder interests dominate; in Web3, community consensus rules. How does HashKey balance these two? The prospectus shows that in 2024, HKD 177 million in HSK incentive costs were recognized, directly impacting current profit figures.

This is a difficult balance and also an innovative possibility. If HashKey can design a mechanism that makes the equity value of the listed company and the token value of the on-chain ecosystem form a positive feedback loop rather than mutual exclusion, it will pioneer a new paradigm for global Web3 companies’ listings and serve as a highly illustrative case for traditional listed companies adopting tokenomics. Conversely, mishandling could lead to pressure from traditional equity investors (demanding profits) and crypto community users (demanding incentives).

I have had multiple in-depth discussions with Dr. Xiao Feng on tokenomics and token value, understanding his persistence and conviction in this direction, and his substantial resource investment and practical exploration. I look forward to HashKey making a groundbreaking contribution in this area.

4. Good guys must win—Can HashKey achieve business success within a compliant framework?

“Being a good person” has never been easy in crypto, especially when your competitors are a bunch of wild, unrestrained offshore giants.

“Compliance” is not only HashKey’s most expensive moat but also its current heavy financial burden. The prospectus shows that in the first half of 2025 alone, compliance costs reached HKD 130 million, directly increasing the net cash outflow from operations. This starkly reveals the cost of “the正规军”: compliance is not a one-time entry ticket but a continuous cash-burning state.

But the problem is: compliance itself does not automatically translate into business success.

The capital market is brutal; it rewards winners, not “good guys.” If HashKey only achieves compliance but cannot turn this advantage into excess financial returns, it becomes an expensive, inefficient financial pipeline.

Therefore, the core question of this point is: can HashKey turn “compliance costs” into “compliance premiums”?

We must face a structural risk: compliance brings higher fixed costs and reduces strategic flexibility. When offshore exchanges can freely list hot Meme coins and offer high-leverage derivatives, HashKey must navigate between jurisdictions like Hong Kong, Bermuda, Japan, and others, responding to increasingly strict AML and KYC requirements. This “dancing with shackles” posture may cause it to fall behind in periods of technological or mode innovation.

If compliance ultimately just becomes an administrative burden, turning HashKey into a traditional bank disguised as a blockchain, losing the efficiency and innovation that crypto should have, then it’s not “good guys winning,” but “good guys being regulated to death.”

To truly “win,” HashKey must demonstrate that for giants like BlackRock and Fidelity, HashKey is the only channel they dare to use to enter Web3. Only when compliance becomes an exclusive advantage that attracts trillions of traditional funds will the high compliance costs be justified as necessary foundations for building a monopoly barrier.

Thus, the truly worth-watching question is not whether HashKey will be “stuck” by regulators, but whether it can establish a healthy interactive relationship with regulation: on one hand meeting increasing compliance demands, and on the other maintaining the core advantages of blockchain—efficiency, transparency, and global reach.

Dr. Xiao Feng mentioned in his letter that they chose “the hardest path.” But the destination of this path cannot merely be moral high ground; it must be business victory. After all, only if “good guys win,” can the industry believe in the power of rules, long-termism, and value.

5. Regional demonstration—Can HashKey explore a long-term crypto path for Asia?

Finally, we must revisit the gene of this “unicorn.” HashKey did not emerge out of nowhere; behind it is Wanxiang Group’s more than a decade-long deep cultivation in blockchain.

From Wanxiang’s early support and investment in Ethereum ten years ago to HashKey’s listing today, this is not just a business story but a long journey of technological perseverance. This “industry capital + technological faith” background fundamentally distinguishes HashKey from those offshore exchanges that chase traffic alone. In Dr. Xiao Feng’s view, blockchain should not merely be a tool for financial speculation but a foundational infrastructure for reconstructing the digital economy.

Under the “one country, two systems” framework, Hong Kong is not only China’s financial firewall but also a sandbox for institutional innovation. HashKey’s mission is essentially to answer a long-standing question in Asia’s economic circle: what kind of crypto does Asia need?

Chinese people have an absolute advantage in offshore exchanges, but after more than ten years, this system has lost its ability to create quality assets and is mired in controversy and criticism.

HashKey is exploring a long-term path with Asian characteristics.

The “Tokenization” business mentioned in the prospectus is the concrete carrier of this route. HashKey aims to demonstrate that under strict regulation, blockchain technology can still generate enormous incremental value, rather than merely engaging in speculative zero-sum games within existing funds.

If HashKey can successfully implement this model, it will provide an extremely important example for the entire Asian and even global markets: compliance is not the opposite of innovation but a prerequisite for large-scale commercial application.

The road ahead remains the “most difficult path.” As Dr. Xiao Feng said in his letter, HashKey did not choose an “easier” route but chose “to build bridges with technology and base on compliance.” We can even reasonably expect that HashKey will, through healthy interaction with regulators, participate in shaping and continuously developing Asia’s crypto regulatory system.

HashKey needs to pass through that narrow door between the arrogance of traditional finance (not understanding Web3) and the wildness of the crypto world (looking down on compliance). This is not only for its own business success but also to demonstrate to Asia and the world: after the bubbles fade, the righteous path remains enduring.