Caitlin Long

Caitlin Long is one of the most consequential figures at the intersection of traditional finance and crypto regulation in the United States. A 22-year Wall Street veteran (Morgan Stanley, Credit Suisse), she became a full-time Bitcoin advocate in 2018, moved to Wyoming, and spent years lobbying the state legislature to create the nation’s most crypto-friendly banking framework. Her flagship project, Custodia Bank, became the epicenter of the US regulatory battle over whether crypto companies could access the Federal Reserve’s payment system — a fight Long is still waging.


Early Career

Long worked on Wall Street for over two decades, including as:

  • Managing director at Morgan Stanley
  • Head of corporate transactions at Credit Suisse
  • Expert in pension liabilities and balance sheet restructuring

Her financial background gave her credibility when she argued that traditional finance’s rehypothecation and fractional reserve practices were incompatible with digital assets’ settlement finality.


Wyoming Blockchain Laws

In 2019, Long co-founded the Wyoming Blockchain Coalition and helped draft a series of bills that established Wyoming as the most crypto-friendly state in the US:

  • HB 70 (2019): Defined utility tokens as property, not securities — directly opposing SEC’s Howey test application
  • HB 74 (2019): Created a new Special Purpose Depository Institution (SPDI) charter for crypto banks — the legal framework Custodia operates under
  • SF 125 (2021): Established aDAO LLC structure allowing DAOs to incorporate in Wyoming

Wyoming’s SPDI charter requires 100% reserve backing (no fractional reserve lending), which Long argued was safer than traditional bank models.


Custodia Bank

Long founded Custodia Bank (originally Avanti Bank) in 2020 as an SPDI holding Bitcoin and dollar deposits with no fractional reserve. Custodia applied to the Federal Reserve for a master account — the key to accessing the US payments system (Fed Funds, Fedwire, etc.).

January 2023: The Federal Reserve Board unanimously denied Custodia’s master account application — the first such denial in the Fed’s history for a state-chartered bank. The Fed cited crypto risks and Custodia’s lack of FDIC insurance.

February 2023: Custodia filed a federal lawsuit against the Fed, arguing the denial was politically motivated and unlawful since SPDIs meet all legal requirements for master accounts.

As of 2024, litigation continues. Long has been publicly vocal that the denial was part of what she termed “Operation Chokepoint 2.0” — a coordinated effort by federal regulators (OCC, FDIC, Fed) to cut crypto companies off from the banking system.


Operation Chokepoint 2.0

Long coined this term, comparing the Biden-era crypto debanking to the Obama administration’s “Operation Chokepoint” that pressured banks to drop customers in disfavored industries (payday lenders, gun dealers). She published detailed documentation of banks receiving informal regulatory pressure to avoid crypto customers.

Her claims gained credibility when multiple crypto-friendly banks (Silvergate, Signature, SVB) failed or were seized in March 2023, concentrated in crypto-lending.


Industry Impact

  • Considered one of the architects of US state-level crypto regulation
  • Named to Forbes’ “Blockchain’s Billion Dollar Babies” list
  • Regular Congressional testimony witness on digital asset banking
  • One of the most followed voices on Bitcoin’s monetary properties on social media

Research

  1. Long, C. (2018). “The Real Story of the Wyoming FinTech Sandbox.” Wyoming Law Review.
  1. Federal Reserve Board (2023). “Denial of Custodia Bank’s Application for a Federal Reserve Master Account.” Board Order, January 27, 2023.
  1. Senate Banking Committee Testimony — Caitlin Long (2022). US Senate.
  1. Harper, J. (2023). “Custodia Bank v. Federal Reserve: A Crypto Banking Lawsuit with Major Implications.” American Banker.
  1. Long, C. (2023). “Operation Chokepoint 2.0.” Substack.