Salud Capital
Salud Capital Research · April 2025
Timely Research · April 2025

U.S. Crypto Regulation in April 2025: The New Framework Is Taking Shape

Trump signed EO 14179 on day one establishing a Crypto Czar and directing the repeal of restrictive guidance. The SEC reversed SAB 121, dropped 89+ enforcement cases, and published a stablecoin non-security statement. The FDIC rescinded its notification requirements. The GENIUS Act is advancing in the Senate. This is the new regulatory environment and what it means for every crypto position.

EO 14179GENIUS ActSEC Task ForceCrypto CzarStablecoinsSAB 122FDIC
✎ Salud Capital Research📅 April 2025⚠ April 2025 snapshot
EO 14179
Day-One Policy
Jan 20, 2025
SAB 122
SAB 121 Reversed
Unlocks bank custody
89+
SEC Cases Dropped
Enforcement pivot
Apr 4
Stablecoin Non-Security
SEC staff guidance
GENIUS Act
Senate Progress
Stablecoin framework
01 · The New Policy Environment

From Enforcement-First to Clarity-First: The 180-Degree Turn

The regulatory environment for crypto in April 2025 is categorically different from twelve months ago. Under Gary Gensler, the SEC filed 89+ enforcement actions and operated on the theory that nearly all digital assets were unregistered securities. Under Acting Chair Mark Uyeda and incoming Chair Paul Atkins, the SEC has dropped most of those cases, reversed SAB 121, published guidance that stablecoins are not securities, and established a Crypto Task Force led by Commissioner Hester Peirce to replace enforcement with rulemaking.

The change started on January 20, 2025, when President Trump signed Executive Order 14179 establishing a “Crypto Czar” (David Sacks as Special Advisor for AI and Crypto) and creating the President’s Working Group on Digital Assets with a mandate to identify and repeal restrictive guidance across all federal agencies within 30 days. The Working Group delivered. By April 2025, four major regulatory reversals have taken effect and more are in process.

The SAB 122 moment was the hinge: SAB 121 required any entity custodying crypto for customers to record it as a liability on their own balance sheet at fair value — making crypto custody economically prohibitive for regulated banks. SAB 122 reversed that. The day it was reversed, the path for JPMorgan, Bank of America, and Fidelity to offer institutional crypto custody without a balance sheet penalty opened. This was the single most important regulatory change for institutional adoption, and most market participants have not fully priced its implications.
02 · Agency-by-Agency Status

What Each Regulator Has Done Through April 2025

AgencyKey Action (Jan–Apr 2025)What It UnlocksStatus
SEC Reversed SAB 121 via SAB 122 (Feb 2025); dropped 89+ enforcement cases; published stablecoin non-security guidance (Apr 4); declared proof-of-work mining non-securities (Mar 20); established Crypto Task Force 2.0 Bank crypto custody; stablecoin issuance without securities registration; mining without SEC oversight Active — Rule-making mode
FDIC Rescinded FIL 16-2022 notification requirement (Mar 28, 2025); FDIC-supervised banks can now engage in crypto activities under standard risk management without prior approval Community and regional banks entering crypto without pre-approval bureaucracy Done — Rescission complete
Federal Reserve Withdrew supervisory letters SR 22-6 and SR 23-8 (Apr 24, 2025); crypto oversight shifted to routine supervision for state member banks State member banks (e.g., Goldman’s bank subsidiary) engaging in crypto without dedicated prior approval letters Done — Letters withdrawn
OCC Reaffirmed bank authority to engage in crypto custody, stablecoin activity, and blockchain network participation under existing charters National bank charters for crypto-native firms; existing banks adding crypto services without special approval In Progress — Charters pending
CFTC Acting Chair Pham deprioritized technical violation enforcement; signaled elevated CFTC role in digital commodity oversight pending CLARITY Act passage DeFi and crypto derivatives with more CFTC oversight and less SEC enforcement uncertainty Evolving — Legislation pending
03 · GENIUS Act & Legislative Status

The Stablecoin Law Is Coming — What It Means

The GENIUS Act (Guiding and Establishing National Innovation for U.S. Stablecoins) is advancing through the Senate in April 2025 with bipartisan support. The bill would create the first comprehensive federal framework for payment stablecoins, requiring issuers to maintain 1:1 dollar reserves, submit to regular audits, register with either the OCC (for non-bank issuers above $10B) or their state regulator (for smaller issuers), and comply with BSA anti-money-laundering requirements.

The most consequential provision for market structure: the GENIUS Act explicitly designates covered stablecoins as not securities under federal securities law. This removes the regulatory overhang that has prevented banks from issuing stablecoins directly and gives institutional payment companies a clear compliance pathway. Circle is already MiCA-compliant in Europe; GENIUS Act passage would give USDC the same regulatory clarity domestically.

🐂 Winners from This Regulatory Environment
Coinbase (COIN): SAB 122 enables institutional custody at scale; enforcement cases dropped; CLARITY Act provides exchange registration pathway
Circle / USDC: Already MiCA-compliant; GENIUS Act creates domestic regulatory pathway; Treasury partnership potential
Bitcoin (BTC): Strategic Bitcoin Reserve executive order; spot ETF inflows accelerating; sovereign reserve asset narrative gaining ground
XRP / Ripple: SEC case near resolution; RLUSD stablecoin positioned for GENIUS Act compliance; XRP ETF filings pending
DeFi protocols: Non-custodial DeFi explicitly excluded from CLARITY Act registration; DOJ deprioritizing developer prosecutions
🐉 Risks & Open Questions
GENIUS Act not yet law; yield-on-stablecoins provision still contested between banks and crypto exchanges
International divergence: EU’s MiCA framework differs materially; cross-border compliance costs remain high
Tether remains unregulated and dominant; GENIUS Act compliance could disadvantage compliant issuers vs. offshore alternatives if not enforced globally
DeFi gray areas remain: CFTC jurisdiction over on-chain derivatives protocols unresolved pending CLARITY Act
CBDC prohibition in EO 14179 closes the door on US digital dollar — cedes that ground permanently to private stablecoins

References

G-01
Executive Order 14179: Removing Barriers to American Leadership in Artificial Intelligence
White House · January 20, 2025 · Crypto Czar establishment; Working Group mandate; 30-day review directive
whitehouse.gov/eo-14179
G-02
SEC Division of Corporation Finance — Statement on Stablecoins
SEC · April 4, 2025 · Covered stablecoins not securities if backed 1:1 by low-risk reserves; registration not required
sec.gov/statement-stablecoins-040425
G-03
FDIC — FIL 7-2025: Rescission of Crypto Notification Requirement
FDIC · March 28, 2025 · State nonmember banks may engage in crypto under standard risk management without pre-approval
fdic.gov/FIL-7-2025
G-04
GENIUS Act (S.394) — 119th Congress
U.S. Senate · 2025 · Federal stablecoin framework; reserve requirements; OCC registration pathway; non-security designation
congress.gov/S.394
G-05
Latham & Watkins — US Crypto Policy Tracker
Latham & Watkins LLP · Updated monthly · Comprehensive tracker of all regulatory actions, no-action letters, and legislative developments
lw.com/us-crypto-policy-tracker