--- title: US 2025–2026 Crypto Policy Reset · Documented Federal Actions aliases: - usa-2025-crypto-reset - trump-crypto-regulatory-reset - sab-121-repeal - bitcoin-strategic-reserve-eo - crypto-enforcement-policy-2025 domain: fintech created: 2026-05-25 last_updated: 2026-07-30 last_tended: 2026-07-30 review_by: 2026-10-30 confidence: certain tags: [fintech, regulatory, usa, 2025-reset, sec, sab-122, executive-order, strategic-reserve, genius-act] status: active sources: - https://www.sec.gov/rules-regulations/staff-guidance/staff-accounting-bulletins/staff-accounting-bulletin-122 - https://www.whitehouse.gov/presidential-actions/2025/01/strengthening-american-leadership-in-digital-financial-technology/ - https://www.whitehouse.gov/presidential-actions/2025/03/establishment-of-the-strategic-bitcoin-reserve-and-united-states-digital-asset-stockpile/ - https://www.sec.gov/newsroom/press-releases/2025-30 - https://www.sec.gov/newsroom/press-releases/2025-47 - https://www.sec.gov/newsroom/press-releases/2025-68 - https://www.sec.gov/newsroom/press-releases/2026-34 - https://www.sec.gov/newsroom/press-releases/2026-30-sec-clarifies-application-federal-securities-laws-crypto-assets - https://www.occ.gov/news-issuances/news-releases/2025/nr-occ-2025-16.html - https://www.fdic.gov/news/financial-institution-letters/2025/fdic-clarifies-process-banks-engage-crypto-related - https://www.federalreserve.gov/newsevents/pressreleases/bcreg20250424a.htm - https://www.govinfo.gov/app/details/PLAW-119publ27 - https://www.occ.gov/news-issuances/bulletins/2026/bulletin-2026-3.html - https://home.treasury.gov/news/press-releases/sb0435 - https://www.banking.senate.gov/newsroom/majority/chairman-scott-senate-banking-committee-advance-clarity-act-in-historic-bipartisan-vote --- # US 2025–2026 Crypto Policy Reset · Documented Federal Actions ## TL;DR From January 2025 through July 2026, the US federal approach to digital assets changed through several legally distinct channels: SEC accounting guidance, presidential orders, bank-supervisory guidance, SEC enforcement and interpretation, enacted stablecoin legislation, and pending market-structure legislation. These actions are collectively useful as a “policy reset,” but they do not have the same legal force. **The GENIUS Act is enacted law; the 2026 implementing rules cited here are still proposals; the CLARITY Act had advanced from the Senate Banking Committee but had not become law as of July 30, 2026.** ## Wiki route This entry sits under [[fintech/INDEX|fintech index]] as the anchor page for the documented US policy changes. Read it with [[fintech/genius-act-501-denylist-mandate|GENIUS Act analysis]], [[fintech/cftc-sec-crypto-jurisdiction|CFTC vs SEC jurisdiction]], and [[fintech/occ-trust-bank-charter-federal-stablecoin-arbitrage|OCC national trust-bank route]]. For comparisons, see [[fintech/global-stablecoin-regulatory-five-pole-matrix|five-pole regulatory matrix]] and [[fintech/mica-overview|EU MiCA]]. ## Verified timeline | Date | Public action | Authority and verified effect | Status at 2026-07-30 | |---|---|---|---| | 2025-01-21 | SEC Crypto Task Force launched | Acting Chair Mark Uyeda created an agency-wide task force led by Commissioner Hester Peirce | Active SEC policy initiative | | 2025-01-23 | SAB 122 issued | SEC staff rescinded SAB 121; SAB 122 became effective on 2025-01-30 | Effective staff accounting guidance | | 2025-01-23 | Executive Order 14178 | Revoked EO 14067, created the President's Working Group on Digital Asset Markets, and directed agencies not to establish, issue, or promote a CBDC except as required by law | Executive order in force | | 2025-02-27 | SEC–Coinbase case dismissed | The SEC filed a joint stipulation to dismiss with prejudice; the SEC expressly said the decision was not an assessment of the merits and did not state its position on other cases | Case dismissed | | 2025-03-06 | Executive Order 14233 | Established the Strategic Bitcoin Reserve and US Digital Asset Stockpile, initially using qualifying forfeited government assets | Executive order in force | | 2025-03-07 | OCC Interpretive Letter 1183 | Reaffirmed specified crypto custody, stablecoin, and node-verification activities as permissible and rescinded the prior supervisory non-objection requirement | Effective OCC interpretation | | 2025-03-28 | FDIC FIL-7-2025 | Rescinded FIL-16-2022 and said FDIC-supervised institutions may conduct permissible crypto activities without prior FDIC approval, subject to ordinary risk management and law | Effective FDIC guidance | | 2025-04-21 | Paul Atkins sworn in | Atkins became the 34th SEC Chair after Senate confirmation on 2025-04-09 | Serving on the date of review | | 2025-04-24 | Federal Reserve guidance withdrawn | The Board withdrew its 2022 advance-notification letter, its 2023 dollar-token non-objection process, and joined withdrawal from two 2023 interagency statements | Prior special processes withdrawn | | 2025-07-18 | GENIUS Act enacted | Public Law 119-27 established a federal and state framework for permitted payment stablecoin issuers | Enacted; implementation underway | | 2025-08-07 | Ripple appeals dismissed | The SEC and defendants dismissed their appeals; the district-court judgment, including the civil penalty and injunction, remained in effect | Appeals resolved, judgment preserved | | 2026-03-02 | OCC GENIUS Act proposal published | Proposed rules for issuers and activities within OCC jurisdiction | Proposed, not final | | 2026-03-17 | SEC crypto-assets interpretation issued | SEC interpretation addressed crypto-asset categories and transactions; the CFTC joined for consistent administration of its statute | Issued interpretation | | 2026-04-08 | Treasury GENIUS Act proposal announced | FinCEN and OFAC proposed AML and sanctions-compliance requirements | Proposed, not final | | 2026-05-14 | Senate Banking Committee advanced H.R. 3633 | The committee advanced its version of the CLARITY Act by 15–9 | Pending legislation; not enacted | | 2026-06-18 | Interagency customer-identification proposal | FinCEN and the federal banking agencies proposed customer-identification requirements for permitted payment stablecoin issuers | Comment period open through 2026-08-21 | Sources: [SAB 122](https://www.sec.gov/rules-regulations/staff-guidance/staff-accounting-bulletins/staff-accounting-bulletin-122), [EO 14178](https://www.whitehouse.gov/presidential-actions/2025/01/strengthening-american-leadership-in-digital-financial-technology/), [EO 14233](https://www.whitehouse.gov/presidential-actions/2025/03/establishment-of-the-strategic-bitcoin-reserve-and-united-states-digital-asset-stockpile/), [SEC Crypto Task Force](https://www.sec.gov/newsroom/press-releases/2025-30), [Coinbase dismissal](https://www.sec.gov/newsroom/press-releases/2025-47), [Atkins swearing-in](https://www.sec.gov/newsroom/press-releases/2025-68), [Ripple litigation release](https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26369), [OCC](https://www.occ.gov/news-issuances/news-releases/2025/nr-occ-2025-16.html), [FDIC](https://www.fdic.gov/news/financial-institution-letters/2025/fdic-clarifies-process-banks-engage-crypto-related), [Federal Reserve](https://www.federalreserve.gov/newsevents/pressreleases/bcreg20250424a.htm), [Public Law 119-27](https://www.govinfo.gov/app/details/PLAW-119publ27), [OCC 2026 proposal](https://www.occ.gov/news-issuances/bulletins/2026/bulletin-2026-3.html), [Treasury 2026 proposal](https://home.treasury.gov/news/press-releases/sb0435), [SEC 2026 interpretation](https://www.sec.gov/newsroom/press-releases/2026-30-sec-clarifies-application-federal-securities-laws-crypto-assets), [Senate Banking Committee vote](https://www.banking.senate.gov/newsroom/majority/chairman-scott-senate-banking-committee-advance-clarity-act-in-historic-bipartisan-vote), and [Federal Reserve proposal docket](https://www.federalreserve.gov/apps/proposals/FR-2026-0005-01/details). ## 1. Accounting guidance: what SAB 122 changed SAB 122 rescinded the interpretive guidance in SAB 121. It tells entities that safeguard crypto assets for platform users to assess recognition under applicable loss-contingency or provisions standards, and to continue making disclosures needed for investors to understand the safeguarding obligation. The narrow wording matters. SAB 122 did **not** itself: - authorize every bank to custody crypto assets; - eliminate prudential capital, safety-and-soundness, consumer-protection, or other legal requirements; or - prove that any named bank launched or expanded a custody product because of the bulletin. Source: [SEC Staff Accounting Bulletin No. 122](https://www.sec.gov/rules-regulations/staff-guidance/staff-accounting-bulletins/staff-accounting-bulletin-122). ## 2. Executive policy: EO 14178 and EO 14233 EO 14178 changed executive-branch policy, created an interagency working group, revoked the prior digital-assets order and framework, and directed agencies to stop specified CBDC work except as required by law. It did not enact a statute or transfer Congress's legislative power to the working group. EO 14233 created two separate holdings: - the **Strategic Bitcoin Reserve**, initially capitalized with qualifying finally forfeited BTC held by Treasury, while other agencies were directed to review their transfer authority; and - the **US Digital Asset Stockpile**, for qualifying non-BTC forfeited digital assets. Bitcoin deposited in the reserve is not to be sold and is maintained as a reserve asset, subject to the order and applicable law. Treasury and Commerce may develop budget-neutral strategies for additional BTC acquisition. The order does not establish that additional BTC was purchased, nor does it create a guaranteed market “price floor.” Sources: [EO 14178](https://www.whitehouse.gov/presidential-actions/2025/01/strengthening-american-leadership-in-digital-financial-technology/) and [EO 14233](https://www.whitehouse.gov/presidential-actions/2025/03/establishment-of-the-strategic-bitcoin-reserve-and-united-states-digital-asset-stockpile/). ## 3. Bank supervision: three agencies, separate actions The OCC, FDIC, and Federal Reserve removed crypto-specific pre-clearance or notification processes on different dates. Their actions did not jointly grant a new universal banking power; each agency addressed institutions and activities within its authority. | Agency | Removed requirement | What remained | |---|---|---| | OCC | IL 1179 supervisory non-objection process | Activities must remain permissible and be conducted with adequate risk management | | FDIC | FIL-16-2022 prior-notification process | FDIC-supervised institutions remain subject to safety and soundness, AML, consumer-protection, and other applicable requirements | | Federal Reserve | 2022 advance notification and 2023 dollar-token non-objection process | Crypto activities are monitored through the normal supervisory process | Sources: [OCC Interpretive Letter 1183 announcement](https://www.occ.gov/news-issuances/news-releases/2025/nr-occ-2025-16.html), [FDIC FIL-7-2025](https://www.fdic.gov/news/financial-institution-letters/2025/fdic-clarifies-process-banks-engage-crypto-related), and [Federal Reserve withdrawal announcement](https://www.federalreserve.gov/newsevents/pressreleases/bcreg20250424a.htm). “Operation Choke Point 2.0” is an industry and political label, not the official name of a single federal program. The agency documents establish the rescinded letters and processes; they do not by themselves establish every broader claim made under that label. ## 4. SEC policy, enforcement, and interpretation The SEC's 2025 Crypto Task Force was charged with helping the Commission draw regulatory lines, provide paths to registration, develop disclosure frameworks, and use enforcement resources judiciously. The Commission also dismissed seven prior crypto-asset enforcement actions during fiscal 2025, according to its fiscal-year enforcement report. Those dismissals must be read case by case. In the Coinbase announcement, the SEC explicitly said its decision was a policy exercise of discretion, not a merits determination and not a statement about any other case. In Ripple, dismissal of the appeals left the district-court judgment in place. These outcomes do not support a claim that all prior legal theories, investor-protection enforcement, or fraud cases were abandoned. On March 17, 2026, the SEC issued a Commission interpretation on the application of federal securities laws to specified crypto assets and transactions. That interpretation is a later and more direct source for the agency's current analytical framework than extrapolations from individual case dismissals. Sources: [SEC Crypto Task Force](https://www.sec.gov/newsroom/press-releases/2025-30), [SEC FY2025 enforcement results](https://www.sec.gov/newsroom/press-releases/2026-34), [Coinbase dismissal](https://www.sec.gov/newsroom/press-releases/2025-47), [Ripple litigation release](https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26369), and [SEC 2026 interpretation](https://www.sec.gov/newsroom/press-releases/2026-30-sec-clarifies-application-federal-securities-laws-crypto-assets). ## 5. GENIUS Act: enacted law, proposed implementation Public Law 119-27 establishes the payment-stablecoin framework. Among other provisions, it: - limits US issuance to permitted payment stablecoin issuers, subject to statutory safe-harbor authority; - requires identifiable reserves backing outstanding payment stablecoins at least one-to-one from an enumerated set of liquid assets; - requires a public redemption policy and monthly publication of reserve composition; - restricts pledging, rehypothecation, and reuse of required reserves, subject to specified exceptions; - requires monthly examination and executive certification of reserve reports; and - bars permitted and foreign payment stablecoin issuers from paying holders interest or yield solely for holding, using, or retaining the payment stablecoin. The statute does **not** state a general ban on all “algorithmic stablecoins,” and it does not impose the previously claimed universal T+1 redemption rule. Its effective date is the earlier of 18 months after enactment—January 18, 2027—or 120 days after the primary federal regulators issue any final implementing regulations. As of July 30, 2026, the cited OCC, Treasury, and interagency customer-identification rules were proposals. They should not be described as completed joint regulations. Sources: [Public Law 119-27](https://www.govinfo.gov/app/details/PLAW-119publ27), [OCC proposed rule](https://www.occ.gov/news-issuances/bulletins/2026/bulletin-2026-3.html), [Treasury AML and sanctions proposal](https://home.treasury.gov/news/press-releases/sb0435), and [interagency customer-identification proposal](https://www.federalreserve.gov/apps/proposals/FR-2026-0005-01/details). ## 6. CLARITY Act: pending market-structure legislation The House passed H.R. 3633 on July 17, 2025. The Senate Banking Committee later advanced its version by 15–9 on May 14, 2026, and additional text remained under debate in July 2026. Committee action is not enactment. Until both chambers pass identical text and the bill is signed or otherwise becomes law, its proposed SEC–CFTC allocation and other provisions should be described in the conditional. Sources: [Congress.gov H.R. 3633 record](https://www.congress.gov/bill/119th-congress/house-bill/3633/all-info) and [Senate Banking Committee vote](https://www.banking.senate.gov/newsroom/majority/chairman-scott-senate-banking-committee-advance-clarity-act-in-historic-bipartisan-vote). ## Evidence boundary The table below separates what the public actions establish from claims that require additional evidence. | Surface | Supported conclusion | Not established by the cited action alone | |---|---|---| | SAB 122 | SAB 121 accounting guidance was rescinded | Named-bank product launches, zero capital impact, or universal custody permission | | Executive orders | Administration policy, working group, reserve and stockpile structure | New congressional authority, completed additional BTC purchases, or a market price floor | | Bank guidance | Crypto-specific prior-notification or non-objection processes were removed | Guaranteed account access, approval of every activity, or absence of normal supervision | | SEC cases | Specified cases were dismissed or appeals resolved | Blanket abandonment of securities law or fraud enforcement | | GENIUS Act | Payment-stablecoin statute enacted | Final implementation of still-proposed 2026 rules | | CLARITY Act | Bill advanced through House and Senate committee stages | Enacted market-structure law | Sources: The supported conclusions map to the primary materials linked in the six sections above. The right column records limits of those same materials, not predictions. ## Related - [[fintech/INDEX|fintech index]] - [[fintech/genius-act-501-denylist-mandate|GENIUS Act analysis]] - [[fintech/genius-act-501-actual-implementation|GENIUS implementation]] - [[fintech/treasury-stablecoin-policy-2025|Treasury stablecoin policy]] - [[fintech/occ-bank-charter-crypto-2025|OCC national bank charter for crypto]] - [[fintech/occ-trust-bank-charter-federal-stablecoin-arbitrage|OCC national trust-bank route]] - [[fintech/cftc-sec-crypto-jurisdiction|CFTC vs SEC jurisdiction]] - [[fintech/global-stablecoin-regulatory-five-pole-matrix|five-pole matrix]] - [[fintech/mica-overview|EU MiCA overview]] - [[exchanges/us-crypto-licensing-multi-layer-system|US crypto licensing layers]] ## Sources - [SEC Staff Accounting Bulletin No. 122](https://www.sec.gov/rules-regulations/staff-guidance/staff-accounting-bulletins/staff-accounting-bulletin-122) - [Executive Order 14178](https://www.whitehouse.gov/presidential-actions/2025/01/strengthening-american-leadership-in-digital-financial-technology/) - [Executive Order 14233](https://www.whitehouse.gov/presidential-actions/2025/03/establishment-of-the-strategic-bitcoin-reserve-and-united-states-digital-asset-stockpile/) - [SEC Crypto Task Force launch](https://www.sec.gov/newsroom/press-releases/2025-30) - [SEC Coinbase dismissal](https://www.sec.gov/newsroom/press-releases/2025-47) - [SEC FY2025 enforcement results](https://www.sec.gov/newsroom/press-releases/2026-34) - [SEC 2026 crypto-assets interpretation](https://www.sec.gov/newsroom/press-releases/2026-30-sec-clarifies-application-federal-securities-laws-crypto-assets) - [OCC Interpretive Letter 1183 announcement](https://www.occ.gov/news-issuances/news-releases/2025/nr-occ-2025-16.html) - [FDIC FIL-7-2025](https://www.fdic.gov/news/financial-institution-letters/2025/fdic-clarifies-process-banks-engage-crypto-related) - [Federal Reserve guidance withdrawal](https://www.federalreserve.gov/newsevents/pressreleases/bcreg20250424a.htm) - [GENIUS Act, Public Law 119-27](https://www.govinfo.gov/app/details/PLAW-119publ27) - [OCC GENIUS Act proposed rule](https://www.occ.gov/news-issuances/bulletins/2026/bulletin-2026-3.html) - [Treasury GENIUS Act AML and sanctions proposal](https://home.treasury.gov/news/press-releases/sb0435) - [Senate Banking Committee CLARITY Act vote](https://www.banking.senate.gov/newsroom/majority/chairman-scott-senate-banking-committee-advance-clarity-act-in-historic-bipartisan-vote)