Mercuryo 2025 Recap: Key Events That Defined Crypto’s Legal Architecture

Before January 2025, U.S. crypto policy wasn’t really policy. It was enforcement that became evident in more than 100 actions over four years. The Securities and Exchange Commission went after Coinbase, Binance, and Ripple using the Howey Test as a catch-all, while banks pulled back after FDIC guidance and SAB 121 made custody a liability. Capital left. Talent followed.

Executive Order 14178 landed on January 23, revoking the 2022 directive that framed crypto as systemic risk. Agencies were told to support lawful digital asset activity through a White House working group. Two moves stood out: a full halt on CBDC development, citing privacy risks, and pressure to narrow token classification to limit SEC overreach.

As a result, banks restarted frozen programs, and DeFi developers got a signal that writing code wouldn’t mean automatic guilt. The narrative shifted from bans to integration.

Mid-January told the story with crypto market cap climbing above $3.7 trillion and Bitcoin back at $100,000, all before the new administration took office. Some sold into the rally, causing prices to dip, though they held above late-2024 levels.

By 2026, the fight had moved from courtrooms to Congress. When the U.S. decides where capital can go, everyone else, especially Europe and Asia took adjusts their maps.

SAB 121 was the rule that kept U.S. banks out of crypto custody. Issued by the SEC in March 2022, it required companies holding digital assets for clients to treat those holdings as liabilities on their balance sheet on a 1-to-1 scale, even though the assets weren’t theirs.

Most banks stayed away since the accounting burden made custody services economically unviable. Congress tried to kill it in 2024 with bipartisan support, but Biden vetoed it.

SAB 122 dropped January 23, 2025, the same day as Trump’s pro-crypto executive order. Companies no longer had to book client crypto as balance sheet liabilities, so banks could treat digital assets like other custodial holdings instead.

The American Bankers Association called it the end of "a misguided policy". BNY Mellon and State Street moved custody pilots into full production, while regional banks announced crypto partnerships within weeks. Bank stocks tied to crypto climbed and Bitcoin stayed up, roughly 30% for the year.

If you ran a crypto company under Gary Gensler, you learned the rules in court. The SEC sued exchanges, rejected ETFs, and issued warnings but never explained how to actually comply. Try to register? No clear process. Ask for guidance? Silence. Judges criticized it as regulation by enforcement while Commissioners Peirce and Uyeda called it out publicly.

Mark Uyeda, now Acting Chairman, announced the Crypto 2.0 Task Force on January 21, 2025, with Hester Peirce leading it. The job wasn’t to sue people but to write rules they could actually follow. Four priorities emerged: clarify token classification, open registration paths, fix disclosure rules, and focus enforcement on fraud instead.

If you held altcoins in February 2025, you felt it. Bitcoin dipped while the rest dropped harder as markets adjusted to new rules and macro noise. But money kept coming in with crypto funds seeing inflows every week of Q1. By mid-year, SEC settled with Ripple, XRP returned to exchanges, and an ETF followed.

Draft rules arrived by summer 2025, signaling the SEC from now to the future is building frameworks for something it expects to last.

From 2022 to 2024, the FDIC didn’t outright ban crypto banking, but it made sure nothing moved. "Pause letters" told banks to stop and wait while FIL-16-2022 required approval before any crypto activity. Approval rarely came, so most banks gave up, and crypto startups lost their accounts in what the industry called Operation Choke Point 2.0.

On February 5, 2025, the FDIC released 175 internal documents showing how the agency had systematically blocked bank crypto activity. Acting Chairman Travis Hill acknowledged that requests from banks were "almost universally met with resistance". Hill killed FIL-16-2022, and FIL-7-2025 finally arrived. Prior approval disappeared while custody, stablecoins, and nodes became permitted by default.

Crypto startups finally got access to stable bank accounts, which allowed regional banks to start exploring custody and lending without fearing regulatory pushbacks.

This change was not reflected in the price charts. It became apparent when attempting to deposit dollars. Fewer delays, fewer excuses. Banks stopped blocking cryptocurrency companies, and the USDC reversed its 2024 decline in March. As expected, venture funding increased by 40% as investors felt secure.

Every time the U.S. took Bitcoin from a criminal case, it sold it through quick auctions. No long-term thinking involved. Other governments took a different approach. El Salvador added Bitcoin to reserves. Others started stockpiling quietly.

The U.S. was sitting on roughly 200,000 BTC and treating it like evidence to dispose of, not an asset to hold.

On March 6, 2025, Trump signed an executive order creating the Strategic Bitcoin Reserve. This marked the first time a major government formally added crypto to long-term reserves. All confiscated Bitcoin now goes there instead of auction. The government can only accumulate through forfeiture, not purchases.

Bitcoin dropped 5.7% in an hour when traders realized no open market buying was coming. The dip didn’t last though. By year-end Bitcoin was up. Analysts credited ETF inflows and the Reserve for reinforcing the "digital gold" story. The Treasury’s job this year is planning how to grow the reserve.

The IRS finalized rules in late 2024 requiring DeFi protocols to report user transactions via Form 1099-DA. The problem was simple: DeFi doesn’t collect names, which made compliance impossible without gutting the technology itself. Projects started preparing to block U.S. users entirely rather than face penalties.

The fix came through Congress when Resolution 25 passed both chambers and Trump signed it on April 10. The CRA nullified the IRS rule and blocked any similar attempt without a new law. DeFi platforms, DEX operators, protocol developers, and wallet providers are no longer classified as brokers with no obligation to issue 1099 forms for on-chain trades.

The existential threat lifted as protocols like Uniswap and Aave could operate normally without geofencing U.S. users or implementing impossible KYC systems. Users remain responsible for reporting their own gains, but without an automated IRS pipeline from every DEX. With the rule gone, DeFi doesn’t have to collect your ID to let you trade.

By 2025, stablecoins were processing trillions annually with no federal oversight. TerraUSD’s 2022 collapse had erased $40 billion overnight while Tether continued operating offshore. The new administration made regulation a priority, and this time Congress delivered.

On June 17, 2025, the GENIUS Act created federal rules requiring licensed issuers, full reserves in cash or Treasuries, monthly disclosures, and legal redemption rights. Foreign issuers had to meet the same standards or stay out.

The shift is already happening in small ways. You can pay for coffee with USDC using Mercuryo as a wallet today, but there is still a way to go. As both the U.S. and Europe build frameworks for private sector stablecoins instead of government-issued digital currencies, this will keep changing fast.

Circle tried to go public once before in 2022 with a $9 billion valuation, but the deal collapsed when the market crashed and regulatory rules didn’t exist yet. They waited, and when stablecoin legislation finally passed in 2025, they tried again.

The listing happened on June 5, 2025 at $31 a share. Demand was so strong the stock opened at $69, touched $103, and closed at $83 after multiple trading halts. It jumped 168% in one day, giving the company a $24 billion market cap in what became the biggest crypto listing in four years.

The IPO raised $1 billion and forced the company to report quarterly results, which builds institutional trust in USDC. This created a sharp contrast with Tether, which remains private and offshore. The move also opened the door for more crypto listings while giving traditional investors a regulated way to access stablecoins.

For years, XRP couldn’t shake the SEC lawsuit over whether it was an unregistered security. By 2025, the new SEC settled the case, and XRP’s status finally cleared, allowing asset managers to move fast on ETF applications.

On November 13, 2025, spot XRP ETFs launched on Nasdaq from Canary Capital, Bitwise, and Grayscale. Within 50 days, they pulled in $1.3 billion with zero outflows as institutions bought heavily. XRP jumped from $1.50 to over $2 as ETFs pulled supply off exchanges. Some analysts started mentioning $3 by 2026.

The door is now open for more altcoin ETFs. XRP became as easy to buy as a stock through brokerage accounts and IRAs, giving institutions with compliance restrictions a regulated way in. For anyone who still thinks crypto is separate from "real" investing, the line keeps disappearing.

While the U.S. reset its crypto framework in 2025, Europe was already ahead with MiCA in full effect, giving the EU a complete framework for exchanges, issuers, and stablecoins. The two approaches aren’t identical, but they share more than either side admits.

Both regions now regulate stablecoin issuers with reserve requirements, redemption rights, and supervisory oversight. The GENIUS Act and MiCA’s e-money token rules aim at the same goal: making stablecoins safe for mainstream use. Both also opened doors for banks to engage with crypto and normalized crypto investment products, though Europe moved earlier with ETPs on exchanges like SIX while the U.S. caught up with spot ETFs in 2024-2025.

The U.S. approach is promotion while Europe’s is protection. The U.S. blocked work on a digital dollar over privacy concerns, but Europe is actively building a digital euro to prevent dollar stablecoins from dominating global commerce.

While the U.S. and Europe built comprehensive crypto frameworks in 2025, Asia became a patchwork of strict bans and innovation hubs, and that fragmentation might actually work in its favor.

Japan quietly amended laws to let banks hold and trade Bitcoin with proper risk management. Megabanks like MUFG, SMBC, and Mizuho started building crypto services while yen-backed stablecoins moved into payment pilots. A proposed flat 20% tax would treat crypto gains like securities, helping APAC volumes grow 69% year-over-year.

Singapore and Hong Kong are racing to become Asia’s crypto capital. Singapore topped Bybit’s 2025 rankings at #1 globally for regulatory clarity, while Hong Kong saw volumes jump 233% as it pulled in 9 new licensed exchanges. Both rolled out stablecoin frameworks requiring full reserves and regular audits.

China reinforced trading bans while pushing the e-CNY digital yuan hard. It hit $7.3 trillion in transactions across 180 million wallets after integrating with WeChat Pay. China’s goal is clear: position the e-CNY as a dollar alternative, showing a completely different philosophy from the West’s approach.

For a long time, crypto operated in a gray zone where governments couldn’t decide what it was, and regulators defaulted to enforcement instead of guidance. Builders left for friendlier jurisdictions while capital followed them out.

2025 changed that through a sequence of decisions that added up to something bigger. The U.S. went from lawsuits to legislation as banks got permission to participate and stablecoins got a federal framework. A sitting president signed an order to hold Bitcoin as a strategic reserve. Japan opened its banking system to crypto while Europe’s MiCA came into full effect.

The work isn’t done since frameworks need testing, and markets will find edge cases that force new questions. But the direction is set. Crypto is no longer a question of "if" but "how". How will banks compete with native platforms? Can stablecoins replace wire transfers? Will tokenization open markets that were always closed?

The companies and people who spent years waiting for clarity finally have it. We started Mercuryo in 2018 when none of these rules existed. Seven years later, the framework is here, and what comes next is why we built it in the first place.