How Trump Rebuilt Crypto’s Future in 100 Days

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Preamble

Analysis background

We wanted to put this analysis together because the pace of change has been overwhelming. Across virtually every corner of the U.S. government, crypto policy has been flipped on its head, and it’s been tough even for insiders to keep track of all the specifics. Every week it feels like another agency is rolling back old rules, ending investigations, or announcing new pro-innovation initiatives.

The catalyst for writing this article was the Fed withdrawing its Letter SR 23-8 / CA 23-5, issued on August 8, 2023, was a de facto restriction on state member banks engaging with dollar tokens, including stablecoins.

The letter required banks to obtain a written supervisory nonobjection before conducting any activity involving the issuance, custody, or transaction of dollar tokens. The process was intentionally burdensome, focusing on risks like operational complexity, cyber threats, liquidity events, and regulatory compliance, and it was a nail in the coffin for US crypto companies. This was one of 4 letters written by the Fed that effectively prevented banks from touching both crypto and stablecoins and formed the backbone of Operation Chokepoint 2.0.

Flashback to the last 8 years

If you haven't tried to start a crypto company in the past eight years, let me explain something: it was near impossible. Banking was cut off. Payment rails were blocked. Investors hesitated. Even basic treasury management became a nightmare. U.S. policy forced legitimate builders offshore, into riskier jurisdictions and weaker financial institutions. It forced users and companies into the arms of shadow banks like FTX, BlockFi, and Celsius, the very places that collapsed and caused the real damage regulators claimed they were trying to prevent.

Post-collapse, we watched huge swaths of the crypto ecosystem shut down. Not because they were scams. Not because they failed on their own. But because Washington strangled their access to the basic infrastructure they needed to survive. The Biden administration refused to give legal access to legitimate US crypto companies to store their assets, gain banking services, and use stablecoins. It was a travesty.

The situation in 2025

Fast forward to 2025, and the picture could not be more different. In just 100 days, the Trump administration has reversed course. Not just compared to Biden, but compared to every prior U.S. administration, including Trump’s own first term.

Across the SEC, CFTC, Treasury, FDIC, OCC, and Federal Reserve, anti-crypto regulations have been withdrawn, enforcement hostility has been dismantled, and the gates have been thrown wide open for innovation.

The result has been nothing short of a renaissance. U.S. crypto companies like Ripple, Coinbase, Circle, and many others are leading a "Made in America" movement, bringing stablecoin projects, blockchain startups, and digital asset markets back onshore.

This article provides a full breakdown of everything that’s changed: organized by agency, mapped by timeline, and compared directly against the Biden-era framework and global regulatory trends. Every claim is backed by primary sources or credible reporting. If you want to understand just how far we've come, and how critical this moment is for the future of crypto in America… keep reading.

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Trump’s White House Leadership and Executive Actions

Let’s start at the top: the White House.

On his first day, President Trump ordered a government-wide regulatory freeze, pausing all pending rules (including independent agencies’ proposals) for 60 days of review. This stopped all last-minute Biden-era initiatives and also signaled that agencies should not defend certain Biden-era regulations in court.

Trump set the tone on day one, telling his government that crypto was not to be unfairly treated and the days of the weaponization of the justice system against legitimate US businesses were over.

Three days later President Trump enacted a broad executive order defining his administration’s crypto policy with Executive Order 14178 “Strengthening American Leadership in Digital Financial Technology.”

This order revoked President Biden’s Executive Order 14067 of March 2022 (“Ensuring Responsible Development of Digital Assets”) and rescinded all directives and frameworks issued under it, including the Treasury’s international engagement framework.

The new EO announced it is U.S. policy to support the responsible growth of digital assets and blockchain technology through protecting individuals’ rights to use public blockchains and self-custody without “persecution,” promoting USD sovereignty via dollar-backed stablecoins, ensuring fair access to banking for lawful crypto businesses, and providing “technology-neutral” regulatory clarity.

The same order established an interagency task force within the National Economic Council “The President’s Working Group on Digital Asset Markets” chaired by Special Advisor for AI and Crypto David Sacks (@DavidSacks).

The goal of the working group was to bring together top officials from the Treasury, DOJ, SEC, CFTC, Fed, DHS, etc. to coordinate crypto policy. It was tasked with a review of all existing regulations and guidance and within 180 days the group must report back with a proposed unified federal regulatory framework for digital assets (including stablecoins), as well as proposals for any needed new laws for Congress.

The Working Group was also directed to explore the creation of a “U.S. Digital Asset Stockpile” effectively a strategic reserve of cryptocurrency seized from criminals – to be held by the government. By March 2025, the White House confirmed plans for a “Strategic Bitcoin Reserve”, with Treasury outlining how forfeited crypto assets will be retained rather than immediately auctioned.

Notably, Trump issued a pardon for Ross Ulbricht (@RealRossU), founder of the Silk Road dark web marketplace. Ulbricht had been sentenced to two life sentences in 2015 in a case wrought with controversy. Trump campaigned on pardoning Ulbricht, first making his promise at the Libertarian Party Convention in May of 2024.

Trump also pardoned the Bitmex corporation and its 3 co-founders, Arthur Hayes (@CryptoHayes), Benjamin Delo (@bendelo) and Samuel Reed, who had previously pled guilty to violating the Bank Secrecy Act for failing to maintain anti-money laundering and know-your-customer programs.

“This full and unconditional pardon by President Trump is a vindication of the position we have always held – that BitMEX, my co-founders and I should never have been charged with a criminal offense through an obscure, antiquated law”“As the most successful crypto exchange of its kind, we were wrongfully made to serve as an example, sacrificed for political reasons and used to send inconsistent regulatory signals.” - Benjamin Delo

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Securities and Exchange Commission (SEC)

Gary Gensler is gone. The bane of our existence for the last 4 years has been replaced with new leadership at the SEC, who have dramatically pivoted from the aggressive “regulation-by-enforcement” posture of the Gensler era to a more accommodative approach focused on formal rulemaking and fraud prevention.

Former Chair Gensler resigned just days before Trump's inauguration and President Trump designated Mark T. Uyeda as Acting Chair. By mid-March, President Trump had nominated former Commissioner Paul Atkins (@PaulSAtkins) as the permanent SEC Chair. He was confirmed by the Senate on April 9, 2025. Just last week at the latest Cyrpto round table, he said our industry “has been stifled for the last several years, and that changes are sorely needed.”

In his first day of Trump’s administration, the SEC announced the formation of a Crypto Task Force (CTF) on January 21, 2025, which would be tasked with drafting a comprehensive regulatory framework. Commissioner Hester Peirce (@HesterPeirce), aka ‘Crypto Mom’, a longtime crypto advocate, was appointed to chair this Task Force.

In early February, Peirce released “There Must Be Some Way Out of Here” which outlined all of the major questions and issues for crypto regulation. Among the priorities are: clarifying the security status of various crypto assets, possibly with safe harbors or no-action assurances for tokens that don’t neatly fit the securities framework; exploring temporary relief for token offerings to trade as non-securities under certain conditions until rules are in place; easing the path for token registrations via modified Reg A+ or crowdfunding rules; updating custody rules so broker-dealers and investment advisers can more easily handle crypto assets; clarifying staking and lending programs vis-à-vis securities law; facilitating crypto exchange-traded funds/products; and even considering a cross-border “sandbox” for controlled experimentation across jurisdictions.

When our industry was yelling high and low they wanted regulatory clarity for the past decade, this is it.

Trump’s first major SEC rollback was formally rescinding SAB 121, which was adopted in March 2022 and had required public companies (including banks and custodians) to record clients’ crypto assets on their balance sheets with a corresponding liability.

SAB 121 forced any company or bank that wanted to hold crypto to also hold a corresponding amount of collateral to back it up. So if a bank wanted to custody $1bn worth of Bitcoin, it also had to have $1bn of cash or other high-quality assets counterbalance. It was such a wild rule because no other asset in the world was treated similarly in the US banking system. Now that it’s dead, banks are planning to custody Bitcoin and Ethereum, as well as issue their own stablecoins. We’re going to see a rapid inclusion of crypto into the banking system writ large.

The other major shift in policy has been the SEC’s approach to enforcement. The agency has dropped cases against Coinbase, OpenSea, Ripple, Robinhood, Dragonchain and other legitimate US crypto companies. Crucially, the SEC specified that dropping the Coinbase case specifically, did “not [reflect] on the merits” but would “facilitate…ongoing efforts to reform and renew [the SEC’s] regulatory approach to crypto.” Acting Chair Uyeda explained that with a new Crypto Task Force underway (see below), it was “time to…develop crypto policy in a more transparent manner” rather than through ad hoc lawsuits. Notably, the SEC has stated that fraud cases will continue – eg. market manipulation or Ponzi schemes remain squarely in the crosshairs*.*

On February 27, the SEC’s Division of Corporation Finance issued a “Staff Statement on Meme Coins,” declaring that bona fide meme tokens (driven by social media and lacking an expectation of profits from others’ efforts) “do not involve the offer and sale of securities.” This marked the first time the SEC formally acknowledged that a category of crypto assets (e.g. Dogecoin-like memecoins) is outside its purview, a stark departure from the prior stance that most tokens could be securities.

The Commission also changed its internal rules to prevent any rogue civil servants or members from going after crypto companies by adopting a final rule requiring full Commission approval for any new formal investigations, rescinding delegated authority that had allowed the Enforcement Division to issue subpoenas on its own.

For the previous 15 years, the Commission had deferred to its various division heads to investigate and bring enforcement cases. In the Biden era government, unchecked bureaucrats pursued a strategy of “regulation by enforcement” where they used their regulatory power to punish political victims. Now a majority of Commissioners must vote to authorize each investigation, a significant check on launching far-reaching cases.

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Banking Regulators (OCC, FDIC, and Federal Reserve)

While the SEC took up most of the airtime for anti-crypto discourse in Biden’s era, the Federal banking agencies arguably had a bigger impact on our industry’s growth, offshore domiciling, and exposure to systemic risk.

Together they led Operation Chokepoint 2.0., an informal but coordinated campaign to systematically restrict crypto companies’ access to the traditional financial system. Without passing any new laws, the FDIC, Federal Reserve, and OCC pressured banks through supervisory guidance, examinations, and unofficial warnings to cut off services to crypto businesses, labeling them as ‘high-risk’ regardless of actual compliance or solvency. This coordination was exemplified by the 2023 joint statements from the OCC, Fed, and FDIC warning that crypto business models pose “safety and soundness” risks.

The strategy mirrored the original Operation Chokepoint under the Obama administration, where politically disfavored industries like payday lenders and firearms dealers were debanked through regulatory intimidation rather than formal enforcement. In the case of crypto, the effect was chilling: several crypto-focused banks collapsed (Silvergate) or were seized (Signature), stablecoin markets destabilized (Silicon Valley Bank), and many U.S. crypto firms were pushed offshore, weakening America’s position in the emerging digital asset economy.

The @FDIC was one of the primary enforcers of Operation Chokepoint 2.0, using backdoor pressure tactics to squeeze crypto-friendly banks out of the financial system. During 2022 and 2023, it issued public warnings against crypto banking and leaned heavily on "reputational risk" during examinations, discouraging even law-abiding banks from servicing crypto clients. Under this regime, Silvergate Bank was effectively forced into voluntary liquidation after regulators pressured its liquidity and client relationships, while Signature Bank was seized outright under the pretext of maintaining financial stability, despite no formal insolvency declaration. Senior figures later admitted these moves were politically motivated to send a message that crypto banking was unwelcome.

With Acting Chairman Travis Hill now leading the FDIC, the agency formally rescinded its prior guidance in March 2025 through FIL-7-2025, which had previously required any FDIC-supervised bank to seek prior approval before engaging in digital asset activities.

Banks are no longer subject to an additional approval layer simply for servicing crypto businesses, so long as they manage traditional safety and soundness risks. Hill has been clear that crypto businesses deserve access to basic banking services like any other lawful industry, and that the FDIC’s prior tactics of chilling the sector were a mistake. The era of informal pressure campaigns and backdoor de-banking, at least at the federal level, has ended.

At the Federal Reserve, the withdrawal of SR 23-8 on April 24, 2025, formally ended the requirement for state member banks to seek supervisory nonobjection before dealing with dollar tokens and stablecoins.

However, critics like Senator Cynthia Lummis (@SenLummis) have pointed out that deeper issues remain.

The Fed’s underlying Policy Statement on Section 9(13) remains in place, still casting Bitcoin and digital assets as “unsafe and unsound,” and the agency continues to slow-roll master account approvals for crypto-forward banks like Custodia (@CaitlinLong_). Although the formal paperwork has improved, the cultural resistance within the Fed’s supervisory ranks persists, meaning that real neutrality toward crypto banking remains a work in progress. The Fed’s representatives reportedly agreed in principle to revisit the tiered master account guidelines that had placed “novel” crypto banks in the most difficult category for obtaining Fed accounts, but no timeline is set yet.

In the final days of the previous Trump administration, then OCC Acting Comptroller Brian Brooks (@BrianBrooksUS) had declared that banks may provide crypto custody services (IL 1170), hold stablecoin reserves (IL 1172), and even operate blockchain nodes or use stablecoins for payments (IL 1174). Biden’s Acting Comptroller Michael Hsu rolled back those letters, mandating that banks could onboard crypto clients only after demonstrating to regulators they could do so safely (a hurdle that effectively froze all activity).

Now led by new Acting Comptroller Rodney Hood, the OCC issued on March 7, 2025 OCC Interpretive Letter 1183that rescinded the previous OCC guidance. Brooks’ regime is back in place and the agency states such extra approval is “no longer necessary,” as the agency’s staff has gained sufficient expertise to supervise crypto activities through normal procedures.

Additionally, the OCC withdrew its participation from the interagency “Joint Statements on Crypto-Asset Risks”that had been issued in 2023. (These joint statements from the Fed, FDIC, and OCC in early 2023 warned banks of risks in crypto and led to a de facto “keep your distance” stance.) By pulling out, the OCC signaled it no longer endorses the prior cautions about crypto-related liquidity and credit risks.

The big question for this Trump administration is: will they permanently enact the “Fair Access” rule (first proposed at the end of Trump’s previous term) to prevent banks from indiscriminately denying services to lawful industries, including crypto firms. We can’t just let these four years be completely undone if a new anti-crypto President is elected.

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Commodity Futures Trading Commission (CFTC)

We didn’t see much from the CFTC last term, but we guess that they will become the main regulator and center of attention for crypto policy hacks. We’re probably going to get a market structure bill for crypto in 2025, and most tokens would then fall under CFTC jurisdiction.

The CFTC under Acting Chair Caroline D. Pham (@CarolineDPham) has moved aggressively to undo the damage caused during the Biden administration.

On February 4, 2025, Pham announced a full reorganization of the CFTC’s Enforcement Division, ending the practice of “regulation by enforcement.” Specialized task forces that targeted crypto activities were disbanded, and the division was streamlined into two broad groups: one focused on complex fraud, and another on retail fraud.

“The CFTC is strengthening its enforcement program to focus on victims of fraud, as well as remaining vigilant for other violations of law. This simplified structure will stop regulation by enforcement and is more efficient. These much-needed changes will maximize the CFTC’s resources to bring more actions to pursue fraudsters and other bad actors, and not punish good citizens. I commend the Division of Enforcement for upholding the CFTC’s mission to protect the American public.” - Acting Chair Caroline D. Pham

This was reinforced by a new Enforcement Advisory issued on February 25, raising the threshold for what violations warrant formal enforcement action, and encouraging voluntary compliance over punishment.

In late March 2025, the CFTC took further steps to reverse Biden-era barriers to crypto market growth by formally withdrawing two major staff advisories. The Division of Clearing and Risk withdrew Staff Advisory 23-07, which had warned clearinghouses to apply heightened scrutiny before clearing any crypto derivatives. Simultaneously, the Divisions of Market Oversight and Clearing withdrew Staff Advisory 18-14, which had imposed additional review procedures for listing new virtual currency futures or options.

With these withdrawals, crypto derivative products are now subject to the same listing and clearing procedures as commodities like oil, gold, or soybeans, rather than being flagged as special risk assets.

At the same time, the CFTC has positioned itself as an active collaborator with the crypto industry through the launch of the “Digital Asset Markets Pilot” program. Announced on February 7, 2025, during a Crypto CEO Forum hosted by the CFTC, this pilot program explores how stablecoins and tokenized assets can be used as collateral in futures and derivatives markets. Major firms like Circle, Coinbase, Crypto.com, and Ripple are participating directly in shaping the pilot’s rules and infrastructure. The CFTC describes this effort as a “sandbox for real markets,” an approach similar to regulatory experiments seen in Singapore and the UK but now rooted firmly inside the U.S. system.

Finally, in April 2025, Acting Chair Pham formally aligned the CFTC with the Department of Justice’s new directive to avoid “regulation by prosecution” for crypto. In a public statement issued on April 8, she directed CFTC staff to ensure enforcement actions target clear instances of fraud or manipulation, not technical registration violations or novel market structures.

The CFTC is shaping up to be the most important regulator for crypto going forward, and also the biggest question mark for the Trump administration’s strategy.

While most crypto tokens are now generally considered commodities, and thus fall under the CFTC’s jurisdiction, there is still no clear framework for how the agency will regulate the spot markets that dominate the crypto economy. The CFTC will also need to deal with how to regulate perpetual futures, and last week requested public comments.

Whether the CFTC chooses to be a light-touch facilitator of crypto innovation or falls back into cautious, risk-averse supervision will determine whether the U.S. finally unlocks the full potential of onshore crypto markets, or whether another round of uncertainty drives the industry offshore once again.

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U.S. Department of the Treasury and FinCEN

The Treasury Department, which oversees both the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC), has sharply pivoted under the Trump administration.

The clearest shift came with the repeal of the IRS’s “DeFi broker” rule. In April 2025, President Trump signed H.J.Res. 25 into law, using the Congressional Review Act to overturn a Biden-era regulation that would have classified decentralized platforms and self-custody users as brokers for tax reporting purposes. The Broker Rule would have effectively killed DeFi in the US, as there was no way for any protocol to come in compliance with the impossible surveillance requirements.

FinCEN’s posture has shifted in parallel. Although it has not formally rescinded prior crypto guidance, the agency has shelved the advancement of some of the most aggressive proposals, such as the long-stalled “unhosted wallet” rule from 2020 that would have imposed strict KYC requirements on private wallet transactions.

In a major reversal, OFAC officially rescinded the 2022 sanctions on Tornado Cash in April 2025, removing the protocol’s smart contracts from the Specially Designated Nationals (SDN) list. The new approach stresses targeting individuals and entities that facilitate illicit activity, rather than sanctioning software code or decentralized technologies themselves.

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Department of Justice (DOJ) and Law Enforcement

The Department of Justice has instituted sweeping reforms that abandon the prior administration’s aggressive use of criminal prosecution to enforce crypto regulation.

On April 7, 2025, Deputy Attorney General Todd Blanche issued the “Blanche Memo,” instructing all U.S. Attorneys to cease pursuing cases that attempt to impose regulatory compliance obligations on the crypto industry through criminal law. Unregistered token issuances, staking programs, or exchange operations that do not involve clear fraud were no longer considered criminal targets. Instead, DOJ prosecutors were directed to focus on traditional criminal offenses like fraud, theft, money laundering, and terrorist financing.

The DOJ also disbanded its National Cryptocurrency Enforcement Team (NCET) in February 2025. NCET, created in late 2021, had led many of the aggressive enforcement actions against the crypto industry under the Biden administration. Its dissolution symbolized a full retreat from the idea that crypto deserved a dedicated strike force.

Importantly, the DOJ also aligned with the Treasury Department’s new targeted sanctions policy, promising that future crypto-related sanctions would be focused narrowly on individuals and illicit actors, not entire technologies like Tornado Cash.

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Conclusion

The Trump administration has brought sweeping changes to the crypto industry in just a few short months. They have implemented radical reforms that opened the gates for U.S. crypto companies, developers, and builders to operate legally and openly here in the United States, a complete 180 from the environment we endured under the previous administration.

I know that with time, many will try to memory-hole what happened during the Biden years, but we shouldn’t forget. The policies enacted at the federal level set our industry back by years. They didn’t protect investors. They didn’t stop fraud. They empowered bad actors while punishing legitimate companies that simply wanted to build and grow.

It is shameful that one political party declared war on our industry, openly campaigned on building an "anti-crypto army," and weaponized banking access, regulatory enforcement, and public messaging against us.

Billions of dollars were lost, banks collapsed, innovation fled overseas, and an atmosphere of hostility poisoned an industry that should have been the pride of American technological leadership.

During that period, the United States could have been setting the global standard for crypto regulation, but instead, it took a draconian, suspicious view that everything in crypto needed to be destroyed.

Thankfully, the tide has turned. We now have a president who openly supports digital assets, understands their importance to the future economy, and wants the United States to be a leader in crypto, AI, and the next generation of innovation.

The Democrats' shortsightedness will be remembered as a historic mistake. This is a multi-trillion-dollar industry, and their attempts to kill it off will ultimately look petty, vindictive, and foolish.

Thank you for reading this extensive investigation into the Trump administration’s early actions on crypto policy. Researching and writing it made clear just how much damage was done, and just how quickly it is now being reversed.

Whether you like Trump personally or not, the reality is simple: he has given our industry new life. We have a window of opportunity to build, expand, and lead. It is up to us to use this time wisely.