End of Operation Bottleneck 2.0 and the Right to Banking Access for Crypto Assets:
In a move with significant repercussions for the digital asset sector, President Trump signed an Executive Order on 08/07/2025 aimed at curbing discriminatory practices by financial institutions against companies in the crypto sector.
The order directly addresses what the industry has dubbed Operation Bottleneck 2.0, an alleged informal campaign by regulators to prevent the sector from accessing essential banking services.
The Technical Focus: Redefining Reputational Risk.
The technical pillar of the order is the direct instruction to the main federal banking regulators, the Federal Reserve, the FDIC, and the OCC, to eliminate the vague concept of reputational risk from their supervision criteria and decision-making processes.
The criticism from the crypto industry and the central point of the order is that this definition allowed regulators to pressure banks to close accounts of cryptocurrency companies based on subjective and potentially ideological justifications, rather than technical and objective risk assessments.
The executive order forces regulators to base their decisions on explicit legal and technical compliance, rather than vague risk perceptions.
Enforcement Mechanisms and Legal Implications:
The order is not just a guideline for the future; it has a retrospective component. Federal agencies and financial institutions, including those regulated by the SBA, will be required to review service denials and account closures of companies in the crypto sector.
If it is determined that these actions were based on ideological biases and not on concrete compliance failures, banking institutions may face sanctions, including fines and the obligation to reopen accounts.
This movement was catalyzed by rising tensions between the crypto sector and the banking system.
Technical Conclusion: From a legal standpoint, the Order establishes the right to banking services.