"Operation Chokepoint 2.0" has never been a conspiracy theory.

Previously declassified internal documents from the Federal Deposit Insurance Corporation (FDIC) show that in 2023, U.S. regulators indeed initiated an organized de-banking campaign against the cryptocurrency industry.

That year, as Silvergate, Signature, and Silicon Valley Bank successively collapsed, regulators restricted banks from providing services to crypto companies through institutional friction, leading to limited liquidity and access in the industry. One of the core tools of this campaign was the Federal Reserve's key policy statement from that year, which classified banks' involvement in stablecoins, on-chain settlements, crypto custody, and other activities as "high-risk innovative activities," imposing additional approval thresholds.

Just yesterday, this blockade was dismantled by the Federal Reserve. The latest news indicates that the Federal Reserve has officially revoked the restrictive policy issued in 2023. This is not a sudden "friendliness" from regulators, but rather a recognition that past isolation strategies can no longer cope with the rapidly evolving on-chain capital flows and industry realities.

Emerging Risks

Over the past year, one fact has become increasingly clear:

• The scale of stablecoins continues to expand.
• On-chain dollar settlements are becoming more frequent.
• Capital flows have not returned to the banking system.

The most important dollar settlement activities are occurring in areas where regulatory reach is weaker. This has caused the isolation strategy, originally intended to "prevent risks," to begin to create systemic hazards in reverse.

It is against this backdrop that the Federal Reserve recently officially revoked the restrictive policy statement from 2023, reintegrating banks' involvement in crypto-related businesses back into the regular prudential regulatory framework.

Custodia's Counterattack

The direct consequence of the isolation policy and Operation Chokepoint is that some crypto banks are unable to access the dollar settlement system. Custodia Bank is the most typical case. This bank, focused on crypto custody, has applied for a Federal Reserve master account for three years but has consistently failed to gain approval, being excluded from the dollar clearing system.

Recently, Custodia has submitted a request for a full court review to the Tenth Circuit Court of Appeals, asking for reconsideration of the previous ruling that denied its master account application. Although a ruling has yet to be issued, this lawsuit itself has become an important window for observing the shift in U.S. regulatory logic: the market can gauge whether regulation is transitioning from "default no" to "compliance entry."

Regulatory "How to Regulate"

Almost simultaneously, the SEC released a statement on "Broker-Dealers Custody of Crypto Asset Securities." The document indicates that regulators are no longer entangled in whether to allow it, but are systematically stipulating:

• How private keys should be managed.
• How blockchain technology risks should be assessed.
• How to respond to extreme scenarios such as 51% attacks and hard forks.

Crypto-related businesses are no longer viewed as "exceptions," but rather as regular risks that can be regulated within the financial system.

Institutional Shift

When looking at recent events together, a clear trend emerges:

• The Federal Reserve has revoked special restrictions on crypto.
• The SEC has provided a custody operation framework.
• The OCC has expanded recognition of stablecoins and custody institutions.
• Regulatory focus has shifted from blocking to structured management.

The regulatory focus has shifted from blocking to structured management; crypto is no longer entirely isolated but is broken down into manageable modules: settlement, custody, clearing, and risk control.

Re-entering the Market

In 2023, U.S. regulators chose to "keep crypto out."

By 2025, they realized that long-term absence itself is the greatest risk.

This is not a victory for one side, but a recognition of reality—when on-chain dollars have become part of global capital flows, the only choice for regulators is not to ignore it, but to re-enter it.

The real change will not be reflected in short-term market trends, but in who is allowed to participate in the next phase of the dollar settlement and custody system.

And this is the core significance of this policy adjustment.

*This content is for reference only and does not constitute investment advice. The market has risks, and investment should be approached with caution.

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