On December 17, 2025, HashKey (3887.HK) successfully listed on the Hong Kong Stock Exchange. HashKey's listing occurred at a historical crossroads. On one hand, the US was aggressively pushing for the legalization of the crypto economy, Wall Street was eager to act, and the trillion-dollar RWA industry was poised for takeoff. On the other hand, at the end of November, the People's Bank of China, together with thirteen other departments, reiterated its commitment to cracking down on speculation in virtual currency trading. At this contradictory moment, HashKey's listing sparked a great deal of emotional interpretation within the industry. Whether positive or negative, everyone agreed that this was not merely a company's listing moment, but also a landmark event marking the "regulation" of the Asian crypto asset industry. HashKey thus became an extremely rare observational sample in the Asian crypto narrative. I just saw Dr. Xiao's letter to all HashKey employees. In it, he said, "This is the most difficult path, but we've walked it correctly together." Reading this, I was deeply moved. I've known Dr. Xiao Feng, the founder of HashKey, for many years. He is a veteran and innovator in the financial industry, and a thought leader in the global blockchain industry. We share many common ideals and values, and in many ways, he is my teacher. For many years, I have followed HashKey's development and am deeply aware of Dr. Xiao's perseverance and hard work at Wanxiang Blockchain for over a decade. Today, we have finally achieved a stage of success, and I am sincerely happy for Dr. Xiao and everyone at HashKey. However, this is not a PR piece, and I have no intention of adding a celebratory message for HashKey. I prefer to offer a cool and prudent perspective at this moment. A while ago, HashKey's prospectus was released, and there has been much interpretation and discussion. The data speaks for itself: while revenue has exploded, it has also been accompanied by losses due to high compliance costs and R&D investment. Many people are asking, what is HashKey's motivation for bearing the high costs of compliance and championing long-termism? Is its future bright? This is indeed an important question, not only concerning HashKey itself, but also the overall direction of the Asian crypto industry. I want to analyze the deep logic and challenges behind HashKey's IPO from five dimensions. 1. Asset Restructuring – Can HashKey Bring High-Quality RWA Assets On-Chain? The current dominant narrative in the entire crypto industry is RWA. After the US Market Structure Act is passed in the first quarter of next year, trillions of dollars worth of RWA assets will be rapidly moved on-chain. This means that by 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. US SEC Chairman Paul Atkins has repeatedly reminded the public that the significance of this event is comparable to the birth of paper securities and the digitalization of securities; it is a revolutionary event in human financial history, akin to "movable type printing." However, it seems that even most financial professionals are rather indifferent to this, let alone the general public. Mainland China has just stated its position, deciding to strictly guard against this trend and not yield an inch, delaying it for as long as possible. But outside of China, the entire Asia region has a vast asset base, hundreds of billions of dollars in funds, and countless outstanding entrepreneurs. Faced with the imminent RWA craze, Asia needs a response. Looking across Asia, only HashKey has taken a compliant stance and responded positively to the RWA challenge. What will HashKey do? One approach, actually the simplest and "safest," is to become a compliant distribution channel for US RWA assets entering Asia. Under this model, HashKey's main task is to introduce RWA products, which have already undergone structural design, legal definition, and risk pricing in the US, to 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 the form of tokens or certificates. The advantages of this path are obvious: clear asset quality, mature regulatory logic, and an existing pricing system. HashKey primarily plays the role of an "onshore compliant gateway," with a highly certain business model and relatively controllable execution risks. HashKey leverages Hong Kong's advantageous geographical location. Its prospectus reveals a key detail: HashKey has partnered with 39 traditional brokerages through its Omnibus account. This means that, theoretically, millions of traditional Hong Kong stock accounts can seamlessly access crypto assets. This is a clever B2B2C approach, directly utilizing the traffic channels of traditional finance. However, the problem is equally obvious—this is a low-risk, low-ceiling path. In this model, Asia only gains technical access to US financial assets but doesn't participate in the core shaping of this asset paradigm shift in the RWA era. The power to define assets, set rules, and narrate financial narratives remains firmly in the hands of Wall Street and the US regulatory system. HashKey ultimately resembles a compliant "channel provider" rather than an infrastructure builder of the RWA era. We also have to consider a question: in the current international landscape of Sino-US rivalry, how high is the regulatory tolerance for operating a marketplace for US assets in Hong Kong? What is the ceiling for this business? Another approach, however, is much more difficult and closer to true "asset-side restructuring"—drawing on Wall Street's experience to cultivate a group of local Asian RWA assets, completing the entire path from compliance on-chain, pricing, to trading. This means that HashKey is not just introducing existing assets, but deeply involved in asset selection, structural design, information disclosure, compliance alignment, and secondary market liquidity cultivation. In other words, it's not about "selling other people's RWA," but about helping Asian assets become RWA. This path presents enormous challenges. First, there are no clear legislative and regulatory rules. Second, Asian domestic assets are generally weaker than US assets in terms of transparency, standardization, legal enforceability, and cross-border regulatory coordination; at the same time, this model also means higher compliance costs, a longer incubation period, and unavoidable low liquidity and high uncertainty in the early stages. From a short-term financial return perspective, this is not a "listed company friendly" path. However, from a longer time scale, this is precisely the key watershed that determines whether HashKey can upgrade from a "compliant trading platform" to "Asian RWA infrastructure." If Asia continues to lack a voice on the asset side in the RWA era, then even if on-chain trading flourishes, it will ultimately just be a marketplace for US assets. Conversely, if a replicable, auditable, and scalable Asian-native RWA on-chain paradigm can be gradually established, then HashKey's role will no longer be merely to follow the trend, but to participate in defining it. Of course, reality isn't always a binary choice. HashKey will likely pursue both paths simultaneously for a considerable period: on one hand, gaining scale and cash flow by introducing US RWA assets; on the other hand, tentatively promoting compliant on-chain experiments with Asian assets on a smaller scale. However, it must be acknowledged that what truly determines its long-term industry position is not which path is faster, but which path goes further. RWA is a revolution on the asset side, not just a product innovation. Whether HashKey can play a role beyond simply being a "channel" in this revolution is the most noteworthy question to be continuously observed after its IPO. 2. Asset Screening Rights – Can HashKey Incubate a Batch of High-Quality Projects for Sustainable Development? Almost all exchanges have told stories of "ecosystem building," but historical results have been less than ideal. The reason is simple: exchange incentive mechanisms naturally favor short-term liquidity over long-term project success rates. HashKey differs in that it faces stronger compliance and disclosure pressures, which theoretically should inhibit "rapid pump-and-dump incubation." The question remains: can a highly compliant environment truly foster Web3 projects with network effects and spontaneous growth capabilities? If it ultimately only incubates projects with low volatility, low narrative, and low risk, the ecosystem might be safer, but it could also be more mediocre. This is a structural tension that all "compliant exchanges" face. In the offshore market, exchanges are often both referees and players, and the listing logic is rife with profit transfers and short-term speculation. Since HashKey has chosen the onshore compliant route, it is destined not to follow this old path. HashKey possesses a unique "full ecosystem closed loop": from VC investment in the primary market to asset management in the secondary market, and then to liquidity support from the exchange. This architecture gives it extremely strong asset screening and pricing capabilities. But what I'm more concerned about is whether it has the courage to say "no" to inferior assets? In Dr. Xiao Feng's letter, he mentioned the need to "set a true long-term example for the entire industry." This means that HashKey needs to maintain strategic focus in a market filled with high volatility and the allure of high returns, incubating and supporting Web3 native projects that truly have technological implementation and a closed-loop business model. This requires not only vision but also the willpower to resist the temptation of short-term profits. For investors, whether HashKey can become an "asset filter" for the Asian market is a key indicator of its core competitiveness. 3. An Experiment in Value Distribution—Can HashKey Explore a New Token Economy Model? Many people may not realize that HashKey's IPO created a world first: it is the world's first company to both issue its own token ($HSK) and list on a mainstream capital market. This means that HashKey is traded on both the stock and cryptocurrency markets: HashKey Group is a listed company (3887.HK), representing shareholder interests and pursuing profits and dividends; while its underlying ecosystem, HashKey Chain, and platform token HSK represent community and ecosystem interests. This brings a highly experimental point of interest—how can a listed company simultaneously operate a token economy? In the Web2 era, shareholder interests are paramount; in the Web3 era, community consensus is king. How will HashKey balance these two? The prospectus shows that HK$177 million in HSK incentive costs were recognized in 2024, which directly affected the profit performance of the financial report for that period. This is a difficult balance, but also a possibility for innovation. If HashKey can design a mechanism that allows the equity value of listed companies and the token value of the on-chain ecosystem to form a positive flywheel, rather than an exclusive relationship, then it will explore a completely new paradigm for the listing of Web3 companies globally, and provide a highly exemplary case for listed companies worldwide to adopt token economics. Conversely, if not handled properly, it may face dual pressure from traditional stock market investors (who demand profits) and crypto community users (who demand incentives). I have had many in-depth exchanges with Dr. Xiao Feng on the topic of token economics and token value, and I am well aware of his persistence and belief in this direction, as well as the significant resources and energy he has invested in thinking and practice. I look forward to HashKey making a world-renowned breakthrough in this direction. 4. Even Good People Can Win – Can HashKey Achieve Commercial Success Within a Compliance Framework? "Being a good person" is never easy in the crypto world, especially when your competitors are a group of wildly growing, 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, compliance costs alone reached HK$130 million, directly exacerbating the net outflow of operating cash flow. This data starkly reveals the cost of being a "regular" player; compliance is not a one-time entry ticket, but a state of continuously burning cash flow. The problem is that compliance itself doesn't automatically translate into commercial success. The capital market is ruthless; it rewards winners, not "good guys." If HashKey merely achieves compliance but fails to translate this compliance advantage into superior commercial returns, then it's simply an expensive and inefficient financial conduit. Therefore, the core question is: can HashKey transform "compliance costs" into a "compliance premium"? We must confront a structural risk: compliance brings higher fixed costs and lower strategic flexibility. While offshore exchanges can freely list the highly sought-after Meme coin and offer high-leverage derivatives, HashKey needs to navigate between different jurisdictions such as Hong Kong, Bermuda, and Japan, dealing with increasingly stringent anti-money laundering (AML) and KYC requirements. Will this "dancing in shackles" posture cause it to fall behind in the cycle of technological or business model changes? If compliance ultimately becomes merely an administrative burden, causing HashKey to become a traditional bank disguised as a blockchain company, losing the efficiency and innovation that crypto should possess, then this is not a case of "good guys winning," but rather "good guys being stifled by regulations." For HashKey to truly "win," it must prove that for traditional financial giants like BlackRock and Fidelity, HashKey is the only channel they dare to use to enter Web3. Only when compliance becomes a unique and exclusive advantage attracting trillions of dollars of traditional capital will those expensive compliance costs be seen as a necessary cornerstone for building a monopoly barrier. Therefore, the real issue worth observing is not whether HashKey will be "stuck" by regulation, but whether it can form a positive interaction with regulation: meeting increasingly stringent compliance requirements on the one hand, and retaining the core advantages of the blockchain system in efficiency, transparency, and global accessibility on the other. Dr. Xiao Feng said in his letter that he chose "the most difficult path." But the destination of this path cannot merely be a moral high ground; it must be a commercial victory. After all, only when the good guys win can the industry believe in the power of rules, in long-termism, and in value. 5. A Regional Example – Can HashKey Explore a Long-Term Crypto Path for Asia? Finally, we must look back at the genes of this "unicorn." HashKey didn't appear out of thin air; behind it lies Wanxiang Group's more than a decade of deep cultivation in the blockchain field. From Wanxiang's early investment in Ethereum ten years ago to HashKey's listing today, this is not just a business story, but a long technological journey. This foundation of "industrial capital + technological faith" determines that HashKey is fundamentally different from offshore exchanges that simply chase traffic. In Dr. Xiao Feng's view, blockchain should not merely be a tool for financial speculation, but rather the infrastructure for reconstructing the digital economy. Under the special framework of "One Country, Two Systems," 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 plaguing the Asian economic sphere: What kind of crypto does Asia truly need? While Chinese investors hold an absolute advantage in the offshore exchange sector, over the past decade, this system has lost its ability to create high-quality assets and is mired in controversy and criticism. HashKey is exploring a long-term approach with Asian characteristics. The "tokenization" business mentioned in the prospectus is precisely the embodiment of this approach. HashKey attempts to prove that, under a strict regulatory framework, blockchain technology can still create enormous incremental value, rather than merely engaging in speculative zero-sum games with existing funds. If HashKey can successfully implement this model, it will provide a crucial template for the entire Asian and even global market: compliance is not the opposite of innovation, but rather a prerequisite for large-scale commercial applications. The road ahead remains the "most difficult road." As Dr. Xiao Feng stated in his letter, HashKey did not choose an "easier" model, but instead chose to "use technology as a bridge and compliance as a foundation." We should even reasonably expect that HashKey can participate in the shaping and continuous development of the Asian crypto regulatory system through positive interaction with regulators. HashKey needs to navigate the narrow gate between the arrogance of traditional finance (inability to understand Web3) and the wildness of the crypto world (disdain for compliance). This is not only for its own commercial success, but also to prove to Asia and the world that after the bubble bursts, the true path of humanity is fraught with hardship.
Miyuki
Weiliang
Alex
Anais
Kikyo
Catherine
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