HKMA requires HK-held reserves, local BoD substance, and licensed issuance — "aligned with standards" is a positioning claim until a regulator actually approves a programmable-compliance issuer. Sandbox participants like JD Coinlink and the Standard Chartered-Animoca consortium have been in queue since mid-2024, so the relevant timeline is license approvals, not vendor rollouts. Whether on-chain rule execution counts as equivalent to a licensed custodian signing off remains the architectural bet, and no major jurisdiction has affirmatively answered that yet.

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