About a year ago, we published an open letter outlining practical, achievable steps an incoming administration could take to make the US the crypto capital of the world, reflecting the positions of the cryptolaw bar. The goal was not to promote crypto as an ideology, but to convey advocates’ perspective on how thoughtful regulatory policy could unlock innovation and ensure that the next generation of financial and internet infrastructure would be built on American soil.
On the anniversary of this letter, as market structure legislation hangs on a knife’s edge, it is worth taking stock. The past year has been unusually eventful for US cryptopolitics, and in many respects the pace and scale of progress has exceeded even our more hopeful predictions. This moment calls for a report card of sorts—one that both acknowledges meaningful achievements and identifies the work that remains if the United States is to maintain and build on its leadership.
To take stock
Our letter focused on three overarching priorities: supporting US-based crypto companies, promoting crypto values in public policy, and cultivating a welcoming domestic business environment for builders and entrepreneurs.
Since then, lawmakers have advanced forward-looking policies across all three fronts. Importantly, much of the progress has come not through sweeping regulatory overhauls alone, but through sustained, pragmatic work at the agency level—work that has begun to replace years of uncertainty with a more coherent regulatory stance. Although the job is far from finished, the overall direction of travel is unmistakably positive.
Support US-based companies (letter grade: A-)
Our letter emphasized that US-based crypto companies need clear, sustainable rules to compete globally. We argued that market structure legislation was essential, but we also highlighted several specific sectors – stablecoins, decentralized finance and the integration of traditional finance – where tailored regulatory attention could unlock major benefits.
On this front, there has been considerable progress.
General traffic rules
Momentum toward comprehensive market structure legislation continues, and Congress is poised to clarify the respective roles of securities and commodities regulators in crypto markets — though it has stalled most recently amid disagreements over stablecoin dividends. While a final regulatory framework is still pending, the direction is clear: public blockchains are no longer regulatory black sheep, but are poised to become a permanent part of the US financial system, deserving of its own fit-for-purpose regulations. As lawmakers approach the finish line on the market structure bill, we encourage them and the industry to resolve remaining disagreements in favor of open, innovative use cases rather than cementing the benefits of established crypto intermediaries such as centralized exchanges. The bill is not perfect, but the diversity of industry stakeholders supporting it is an endorsement that it is good enough – and urgent enough – to become law.
Stablecoins
Here the progress has been particularly remarkable. The passage of the stablecoin legislation and the commencement of initial rulemaking has provided long-awaited clarity around issuance, reserves and oversight. This has given several US companies a viable path to compete with offshore issuers, while protecting consumers from weak or opaque reserves and strengthening the dollar’s primacy in global digital markets. But some of those victories are now in jeopardy as the big banks try to reopen the Genius Act during market structure negotiations. Furthermore, regulators must remain clear not to reduce crypto’s disintermediated infrastructure to merely being the back-end for centralized stablecoin issuers.
Traffic integration
The past year has also seen significant steps towards integrating crypto infrastructure into traditional financial markets. Banks, fintechs, asset managers and market intermediaries now operate with greater confidence that responsible engagement with digital assets will not invite reflexive regulatory backlash. This has opened the door to wider institutional participation, improved market plumbing and more robust financial rails. Unbelievably a year ago, key regulators including the SEC, CFTC and OCC are preparing a financial system defined by tokenized securities, new on-chain asset classes and even decentralized finance, promising to work together to streamline regulation for so-called “super apps” that span securities and commodities trading and other innovative products.
DeFi
Decentralized finance remains the most challenging category to regulate, but the conversation has matured. Regulators are increasingly recognizing that DeFi protocols do not fit neatly into frameworks designed for intermediaries, and efforts to separate infrastructure (and its developers) from activity are bearing fruit. However, in codifying a control standard that distinguishes decentralized from centralized finance, lawmakers should be careful not to draw the line so rigidly that DeFi protocols are discouraged from adopting basic security and compliance measures, such as asset curation and sanctions screening, that are necessary to protect users and comply with the law.
Much of this progress can be traced back to exceptionally visionary leadership at the Securities and Exchange Commission. Under new leadership, the SEC has moved away from regulation by enforcement and toward a serious effort to modernize securities law for a tokenized world. This shift — now echoed by the CFTC — has done more than any single policy initiative to restore confidence among American builders. Still, legislation insulated from political cycles and changes in agency leadership is needed to cement those gains, and the window to do so is closing fast.
Crypto values (letter grade: B+)
Crypto is not just a set of disruptive technologies; it is also a deeply American ideology rooted in openness, permissionless innovation, censorship resistance and individual autonomy. In our open letter, we argued that this meant crypto should be treated the same as other technologies in some contexts and differently in others.
Encouragingly, over the past year, crypto-values have begun to feature more prominently in policy discussions and proposed legislation, such as around self-care and privacy. That said, tensions remain. Cryptopolitics still oscillates between libertarian instincts and reflexive containment driven by legitimate governmental concerns about illicit financing, tax evasion and national security. We remain convinced that crypto-native solutions, such as zero-knowledge proofs and portable identities, offer constructive alternatives to well-known regulatory approaches that rely on financial surveillance of financial intermediaries.
Over the past year, regulators have made tangible progress in a number of important areas, such as repealing the IRS DeFi Broker Rule and reigning in OFAC enforcement, but other notable areas, such as a comprehensive tax overhaul that does not unfairly penalize crypto’s open and permissionless architecture, continue to lag.
Progress here is real, but uneven. Continued industry engagement will be critical to ensure that core crypto values are not gradually eroded through well-intentioned but obtuse regulation aimed at making things easier for regulators and traditional businesses. After all, crypto was not born to help the government, optimize finance or streamline applications. It was born to set people free. Regulation should not eradicate this core principle by concentrating network sovereignty in the hands of the state or closed platforms, thereby sidelining the self-governing communities of builders and users it was intended to serve.
A welcoming business environment (letter grade: B)
A year ago, we argued that regulatory clarity alone would not be sufficient to attract and retain crypto-entrepreneurs. Builders also need a business environment that is predictable, fair and competitive with jurisdictions that have actively courted digital asset innovation.
The administration has made meaningful progress on this front. The tone has changed decisively from hostility to engagement. Entrepreneurs are less susceptible to bureaucratic whims and are more likely to encounter regulators who engage constructively rather than punitively. In particular, the OCC’s recent decision to grant national trust charters to fintechs and stablecoin issuers, as well as ongoing discussions about thin master accounts, is an endorsement that blockchain-based companies should operate on an equal footing with traditional financial firms.
Still, the structural challenges remain. State-by-state fragmentation continues to impose real costs on startups. And while the overall posture is more inviting, it hasn’t yet translated into a truly frictionless environment for early-stage builders. For example, despite the availability of DUNAs and 501(c)(4)s as domestic token stewards, projects continue to rely on offshore structures for tax reasons and greater certainty around public token sales.
Room for improvement
Despite the overwhelmingly positive trajectory, the past year has also emerged with important cautionary lessons.
One development we did not foresee was the extent to which the president’s own family would become directly involved in crypto markets. Our original letter was published just days before the launch of a high-profile memecoin associated with the Trump brand. Whatever one thinks of memecoins as a category, this episode underscored the need for clear ethical safeguards to prevent the appearance—or reality—of conflicts of interest that could undermine public confidence in comprehensive cryptopolitics.
More broadly, the next phase of US crypto leadership will depend less on regulators and more on developers themselves. Politics has opened doors; now it is up to entrepreneurs to go through them. The coming years will test whether crypto can deliver on its long-promised use cases: faster and cheaper payments, open capital markets, user-owned platforms, and programmable financial infrastructure that serves real financial needs.
Looking ahead
If the past year has shown anything, it’s that progress is possible, and when it comes, it can be fast.
The challenge now is to consolidate these gains – to finish work on market structures legislation, deepen commitments to privacy and decentralization, and translate regulatory clarity into tangible economic growth. If builders have their way, the US will not only host crypto innovation; it will be the driving force behind it and shape its future.
A year ago, becoming the crypto capital of the world felt purely aspirational. Today, that feels achievable — provided lawmakers and industry players remain clear-eyed, principled and ambitious about what comes next.
Ivo Entchev, Olta Andoni, Stephen Rutenberg, Donna Redel
The views represented and reflected herein are those of the signatories and not necessarily those of their employers.
