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English Premier League football club Chelsea’s lucrative new front-of-shirt sponsorship deal with a stablecoin issuer has left Hong Kong fans and retailers concerned about whether wearing or selling the top counts as illegal promotion under digital currency laws.
Chelsea signed the deal with Circle to feature its USDC stablecoin brand on player jerseys for the 2026-27 season in late August, just three months after the UK’s Financial Conduct Authority (FCA) warned Premier League clubs about partnering with unauthorised crypto and finance businesses.
Circle’s UK arm, Circle UK Trading, is an FCA-regulated company providing certain financial services. But USDC is not issued or regulated under the laws of the United Kingdom, nor is it distributed by a licensed stablecoin issuer in Hong Kong.
Only two stablecoin issuers are currently licensed in Hong Kong – Anchorpoint Financial Limited and HSBC.
Ahead of the enactment of the Stablecoins Ordinance on August 1, 2025, the Hong Kong Monetary Authority (HKMA) warned on its website that “it will be illegal for any person to … actively market the issue of unlicensed [fiat-referenced stablecoins] to the public”.
Winnie Choi, a Chelsea fan of 12 years, was among those worried about breaking the law.
“After looking up the law, I still do not understand whether it is a problem to wear the jersey,” she said.
Choi suggested that the HKMA issue a clear, “down-to-earth” guideline on whether wearing the shirt with the USDC logo constituted promotion.
Danny*, a club supporter for more than 20 years, said ordinary football fans would not have the awareness to identify if the shirt promoted an unregulated stablecoin.
“If I wear it, who will enforce the law? Will I be arrested by police?” he said.
Danny said he would not buy the new jersey until authorities clarified whether it was legal to wear it.
Hammer Chung, owner of football apparel shop DirectSoccer in Mong Kok, said he was unsure whether it was legal to sell replica jerseys with the USDC logo.
He added that he hoped regulators would clarify the matter.
But Chung noted that many of the kits for other football clubs that he sold also bore the logos of illegal gambling websites.
“Are we also promoting for them by selling the shirts?” he said.
The HKMA said it would not comment on individual cases, but noted the ordinance prohibited the “active marketing” or advertising of unauthorised stablecoin activity in Hong Kong.
Whether an act constituted actively marketing to the public was determined on a case-by-case basis, a spokesman said.
Factors considered by the HKMA included the languages used in the marketing messages, whether they targeted people living in the city, whether a Hong Kong domain name was used and whether a detailed marketing plan was in place to promote the activity.
A specific exemption was provided to publishers and live broadcasters who merely published content created by others, as long as they satisfied the relevant conditions set out in the provision and considered the relevant facts and circumstances, he said.
Blockchain expert Louis Li Sze-chung expressed concerns that fans donning the new Chelsea shirt in public could be “problematic”, as it all depended on how the HKMA defined active marketing.
“There are so many grey areas,” he said, adding that he dared not wear T-shirts sporting the logos of unlicensed crypto trading platforms after the licensing regime was put in place by the Securities and Futures Commission (SFC).
Li said USDC was the second-largest stablecoin in the world, and it was ridiculous that it was labelled as “unlicensed” under local legislation.
He also said it was difficult to regulate the promotion of cryptocurrencies within a certain jurisdiction in the age of the internet because they were issued globally. “How can you say something legal in other countries is illegal here?”
The ordinance provides an exemption for promoting unlicensed stablecoins across various media and digital platforms, including live broadcasts, provided the person did not devise and exercised no control over the content of the advertisement.
“A group of players on TV is wearing [shirts with] this logo … it’s impossible that it isn’t an advertisement. We’re looking at them the entire game, right?” Li said.
Tanna Chong, head of public policy at VerifyVASP, a digital assets compliance company, called for enhanced consumer protection through disclaimers before every match, similar to warning messages in moneylending advertisements.
“They would be clear reminders that the programme contains these materials [about cryptocurrency], and that those companies actually do not have a licence in Hong Kong,” she said.
Chong, who helped draft the ordinance during her time in government, said there was no hard and fast rule to define active marketing, noting that it was a concept determined on a case-by-case basis considering various contextual factors.
She said neither Circle nor Chelsea had control over the broadcasting of matches in Hong Kong, which involved a deal between NowTV and the Premier League, and had not actively implemented a marketing campaign in the city.
Circle was not “by way of business providing services” in the city either, she added.
She also reassured fans that there was no problem with wearing the Blues’ shirt with the USDC logo, as wearers were not the service provider.
“Unless [the wearer] is a Circle employee walking down the street in a Chelsea jersey. In that case, you need to establish that Circle instructed him to wear it with the intent of targeting a Hong Kong audience,” she said.
An HKT spokesman said Now TV strictly complied with all relevant Hong Kong laws and regulations.
The South China Morning Post has reached out to Circle and Chelsea FC for comment.
The West London club’s latest deal followed a collective agreement by all 20 Premier League clubs to phase out front-of-shirt gambling sponsors. But the Blues are not the first team to partner with the crypto sector.
OKX and Kraken, both virtual asset trading platforms unlicensed in Hong Kong, are the sleeve sponsors of Manchester City and Tottenham Hotspur.
Chelsea itself also partnered with crypto platform BingX, which is also unlicensed in Hong Kong, for an official training kit front sponsorship.
During their visit to the city last month, Chelsea players wore the training kit with the BingX logo during an open training session at Kai Tak Stadium.
Players from City and Spurs also wore kits sporting the OKX and Kraken logos during their friendlies in Hong Kong in August this year and July last year, respectively.
Similar clauses regulating the promotion of unlicensed virtual asset trading platforms are present in the Anti-Money Laundering and Counter-Terrorist Financing Ordinance.
The SFC said it would not comment on specific cases. It added that it would take into account all marketing and advertising activities in their totality in considering the appropriate course of action.
Kraken said that it maintained jurisdiction-specific controls designed to ensure its activities complied with applicable local laws.
The trading platform also stressed that its partnership with Tottenham Hotspur was a global brand sponsorship.
It did not reflect an offer, solicitation or promotion of Kraken’s virtual asset trading services in jurisdictions where those activities were restricted, it added.
The SCMP has reached out to Manchester City, OKX, Tottenham Hotspur and BingX for comment.
*Name changed at interviewee’s request.
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