Crypto Gloss

Caitlin Long

Caitlin Long is a 22-year Wall Street veteran (Morgan Stanley, Credit Suisse) who became one of the most consequential figures in US crypto banking regulation — co-authoring Wyoming’s landmark blockchain banking legislation in 2019 that created the nation’s most crypto-friendly state banking framework, founding Custodia Bank (the first crypto-native state-chartered bank to apply for Federal Reserve master account access), and leading a high-profile legal fight after the Federal Reserve denied that application in what Long characterized as politically motivated debanking of the crypto industry.

Early Career

Long worked on Wall Street for over two decades:

  • 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 are incompatible with digital assets’ settlement finality — a recurring theme in her advocacy work.

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 the Special Purpose Depository Institution (SPDI) charter for crypto-native banks — the legal framework Custodia operates under
  • SF 125 (2021): Established a DAO LLC structure allowing DAOs to incorporate in Wyoming

Wyoming’s SPDI charter requires 100% reserve backing (no fractional reserve lending) — Long’s argument that this makes it categorically safer than traditional fractional-reserve banks.

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 US payment rails (Fedwire, FedACH).

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-related risks and Custodia’s lack of FDIC insurance.

February 2023: Custodia filed a federal lawsuit against the Federal Reserve, arguing the denial was politically motivated and legally unlawful. Litigation continued through 2024.

Operation Chokepoint 2.0

Long coined this term, drawing parallels between the Biden-era regulatory pressure on crypto banking and the Obama administration’s “Operation Chokepoint” — a program that pressured banks to drop customers in politically disfavored industries (payday lenders, gun dealers).

Long documented banks receiving informal regulatory pressure to avoid crypto clients. Her claims gained credibility when Silvergate, Signature Bank, and Silicon Valley Bank — the three US banks most engaged with crypto — all failed or were seized in March 2023 in circumstances that many in the industry attributed to regulatory pressure.

Industry Recognition

  • Co-architect of Wyoming’s SPDI banking framework (widely regarded as the most sophisticated state-level crypto banking law in the US)
  • Forbes “Blockchain’s Billion Dollar Babies” list
  • Regular Congressional testimony witness on digital asset banking legislation
  • One of the most followed voices on Bitcoin’s monetary properties and US regulatory policy

History

  • Pre-2018 — Two decades at Morgan Stanley and Credit Suisse; focus on balance sheet restructuring and pension liabilities
  • 2018 — Publicly becomes a Bitcoin advocate; writes extensively on crypto and traditional finance
  • 2019 — Co-founds Wyoming Blockchain Coalition; HB 70 and HB 74 pass, creating SPDI framework
  • 2020 — Founds Avanti Bank (later Custodia Bank) under Wyoming SPDI charter
  • 2021 — Custodia applies to Federal Reserve for master account access
  • January 2023 — Federal Reserve unanimously denies Custodia’s master account application
  • February 2023 — Custodia files federal lawsuit against the Federal Reserve
  • March 2023 — Silvergate, Signature, and SVB fail; Long’s “Chokepoint 2.0” framing gains widespread coverage
  • 2024 — Litigation continues; Long remains one of the most prominent voices in crypto banking regulation

Common Misconceptions

  • “Wyoming’s SPDI charter allows crypto banks to take risks traditional banks can’t.” — The opposite: Wyoming SPDIs are required to maintain 100% reserves (no fractional reserve lending), making them theoretically more conservative than traditional fractional-reserve banks.
  • “The Federal Reserve’s denial of Custodia’s master account was routine.” — The Fed had never before denied a master account application from a state-chartered bank that met the legal requirements. Custodia and Long characterized the denial as unprecedented and politically motivated.

Social Media Sentiment

  • r/Bitcoin / r/CryptoCurrency: Long is widely respected in Bitcoin circles for her Wyoming legislation work and advocacy; the Custodia Federal Reserve lawsuit is referenced in regulatory discussions.
  • X/Twitter: Very active; publishes detailed threads on Federal Reserve policy, “Operation Chokepoint 2.0,” and crypto banking law; has a substantial following among Bitcoin-focused investors and policy observers.
  • Discord: Referenced in regulatory and Bitcoin communities; her Congressional testimony is shared in policy-focused channels.

Last updated: 2026-04

Related Terms

See Also

  • Brian Brooks — fellow pro-crypto regulatory pioneer who built the OCC framework at the federal level during the same period
  • Wyoming SPDI — the Special Purpose Depository Institution charter Long helped create
  • Operation Chokepoint 2.0 — the regulatory debanking campaign Long named and documented

Sources