Over the past several years, US crypto policy has reflected two competing regulatory approaches in Washington. Under the Biden administration, agencies took an enforcement-forward posture, with the Securities and Exchange Commission (SEC) bringing high-profile actions against digital asset platforms and market participants such as Coinbase1 and Binance,2 while the Department of Justice pursued criminal enforcement against Binance3 and its founder4 for anti-money laundering (AML) and sanctions violations. At the same time, the Department of the Treasury addressed these same AML and sanctions risks through guidance.5 This approach, often described as “regulation by enforcement,” left industry participants navigating evolving interpretations of law rather than working within a tailored regulatory framework.