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Wyoming-chartered Custodia Bank challenges Federal Reserve’s master account veto power

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Wyoming Crypto Bank petition headlines a rapidly intensifying legal confrontation that could reshape how crypto banks access the U.S. financial system. Wyoming-chartered Custodia Bank has formally petitioned the full Tenth Circuit Court of Appeals to review the Federal Reserve’s denial of its master account, escalating a five-year fight with sweeping implications for federal power, state banking authority, and digital asset innovation. Wyoming Crypto Bank petition filings submitted on December 15 request an en banc review, asking all active judges on the Tenth Circuit to reconsider an October panel ruling that upheld the Fed’s decision. Custodia argues the panel misread federal law and endorsed a system that grants regional Federal Reserve Banks unchecked discretion over legally eligible state-chartered institutions. Wyoming Crypto Bank Petition Challenges Fed’s Master Account Authority At the heart of the Wyoming Crypto Bank petition is the Federal Reserve’s refusal to grant Custodia access to a master account—an essential gateway to core payment rails such as wire transfers and automated clearinghouse (ACH) services. Without it, Custodia says its Wyoming-issued charter is effectively rendered meaningless. Custodia contends the ruling conflicts directly with the Monetary Control Act (MCA), which states that Federal Reserve services shall be available to nonmember depository institutions. The bank argues the Fed has transformed that mandate into what it calls an unconstitutional veto over state banking decisions. When the Fed denies a master account to a state-chartered financial institution, it effectively vetoes a bank charter that State regulators have approved, Custodia wrote in its petition. State Banking Authority Under Threat The Wyoming Crypto Bank petition also raises serious federalism concerns. Wyoming chartered Custodia in 2020 as a Special Purpose Depository Institution (SPDI), a regulatory framework specifically designed to attract digital asset firms while minimizing systemic risk through 100% reserve backing and a prohibition on lending. Custodia argues the Fed’s rejection undermines Wyoming’s carefully constructed regulatory regime and erodes states’ constitutional authority to charter banks. The petition warns that allowing the Fed such power could discourage innovation-driven state banking models nationwide. Constitutional Red Flags in the Wyoming Crypto Bank Petition Beyond federalism, the Wyoming Crypto Bank petition pushes into constitutional territory. Custodia’s legal team argues that if regional Federal Reserve Bank presidents possess unreviewable discretion over master accounts, they effectively function as “Officers of the United States” without proper constitutional appointment. Federal Reserve Bank presidents are selected by private bank directors and approved by the Board of Governors. Custodia says that structure violates the Appointments Clause if those officials wield significant executive authority. Judicial Split Deepens Over Wyoming Crypto Bank Petition The petition highlights a growing divide within the Tenth Circuit itself. Judge Timothy Tymkovich’s dissent in Custodia’s case aligns with Judge Robert Bacharach’s earlier opinion in Fourth Corner Credit Union v. Federal Reserve Bank of Kansas City, creating a 2-2 split among circuit judges. Tymkovich warned that the Fed’s interpretation grants “unreviewable discretion” that contradicts the plain language of the MCA and raises “thorny questions” under Article II of the Constitution. Fed’s Own Records Undermine Denial Rationale The Wyoming Crypto Bank petition also points to contradictions within the Federal Reserve’s own process. The Kansas City Fed denied Custodia’s application in January 2023 after a 27-month review, citing risks tied to “crypto-asset activities.” Yet internal documents show Fed staff initially found Custodia’s capital levels “adequate” and praised its leadership as “impressive.” Custodia says the decision only shifted after intervention by the Board of Governors. Federal Reserve Governor Christopher Waller later acknowledged publicly that the Fed has sufficient supervisory tools to manage risk without blanket denials. In an October interview, Waller said the Fed can “tailor” master account structures to fit a bank’s specific risk profile. Wyoming Crypto Bank Petition Lands Amid Crypto Debanking Reckoning The Wyoming Crypto Bank petition arrives as regulators face mounting scrutiny over crypto debanking. In December, the Office of the Comptroller of the Currency revealed that all nine of the largest U.S. banks imposed “inappropriate” restrictions on lawful businesses, including digital asset firms, between 2020 and 2023. Institutions such as JPMorgan Chase, Bank of America, Citibank, and Wells Fargo maintained internal policies that escalated or restricted entire sectors, reinforcing claims of systemic exclusion. If the full Tenth Circuit agrees to hear the Wyoming Crypto Bank petition, the outcome could redefine the balance of power between state banking regulators and the Federal Reserve—setting a precedent that reaches far beyond Custodia and Wyoming. For the crypto industry, the case may determine whether compliance-focused digital asset banks can ever gain equal footing within the U.S. financial system.Wyoming Crypto Bank Petition Sparks High-Stakes Legal Showdown as Fed Power Faces Fierce Constitutional Test

Wyoming-chartered Custodia Bank challenges Federal Reserve’s master account veto power

12/16/2025
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Whale dumps AI agent tokens at 90%+ loss, exposing thin liquidity in niche markets

Forced liquidation of Ai agent tokens wiped out over 90% of capital, raising fresh questions about market depth and risk oversight.

by Moses Edozie
3 hours ago
in Crypto News
Reading Time: 3 mins read
0
DWF Labs is placing a bold bet on the transformative power of AI agents | Photo: freepik

DWF Labs is placing a bold bet on the transformative power of AI agents | photo: freepik

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A large cryptocurrency holder sold a portfolio of AI agent tokens at losses exceeding 90% in mid-December, triggering price declines of up to 50% across thinly traded markets and highlighting liquidity risks in speculative crypto sectors.

The sell-off, tracked by blockchain analytics firm Ember, unfolded across decentralized liquidity pools with shallow order books, demonstrating how quickly prices can collapse when large positions meet limited buyer demand. Several tokens linked to the Virtuals AI ecosystem suffered near-total value destruction during the liquidation.

Ai agent tokens and the anatomy of a whale exit

On-chain data published by Ember shows the whale accumulated exposure to Ai agent tokens earlier in the year, during a period of peak enthusiasm for artificial intelligence-linked crypto projects.

These assets are typically associated with autonomous trading bots, AI-powered execution tools, and experimental agent-based systems promoted as the next frontier of decentralized finance.

As market conditions deteriorated, the whale moved to close positions in rapid succession rather than through a gradual unwind. Ember reported that losses ranged from roughly 84% to as high as 99%, depending on the token. According to the firm, two assets tied to the Virtuals ecosystem suffered near-total value destruction during the liquidation.

In its on-chain assessment, Ember described the episode as involving “84%–99% losses,” underscoring the severity of the drawdown — Ember, blockchain analytics firm. The data indicates that the wallet’s activity coincided with declining liquidity and waning investor interest across the AI narrative segment of the market.

Liquidity stress hits Virtuals-linked Ai agent tokens

The impact of the sell-off was immediate. As the whale’s tokens moved through liquidity pools, prices across multiple Ai agent tokens fell between approximately 8% and nearly 50% intraday, according to Ember’s analysis.

Screenshots from blockchain explorer Arkham showed a sequence of large transfers between the whale’s address and liquidity pools, with tens of millions of tokens moving in quick succession.

Arkham’s transaction data pointed to what it characterized as “a complete exit rather than a gradual rebalancing of positions,” — Arkham, via blockchain explorer data. This pattern mattered because the markets involved were ill-prepared to absorb such volume without significant slippage.

Several of the hardest-hit assets were linked to the Virtuals ecosystem, a cluster of AI-driven projects that gained traction during the broader artificial intelligence boom.

One AI-powered art and curation project fell about 84% from the whale’s entry price, while another Virtuals-linked agent token declined by roughly 90%, according to the breakdown shared by Ember.

Market lessons from the Ai agent tokens sell-off

For crypto investors, the episode illustrates a familiar but often underestimated risk: narrative strength does not guarantee liquidity resilience.

Many Ai agent tokens launched amid intense hype but failed to build deep, durable markets capable of supporting large exits. When sentiment turned, the lack of buyers amplified losses for large holders and accelerated price declines for smaller participants.

Ember noted that the liquidation “hit shallow order books,” a phrase that captures why even modest selling pressure can cascade into outsized moves in niche crypto segments — Ember, blockchain analytics firm.

For policymakers and regulators monitoring digital asset markets, the event offers a case study in how concentrated ownership and thin liquidity can interact to destabilize prices without any broader systemic shock.

The broader AI token sector has already seen reduced trading volumes and fading enthusiasm compared with earlier in the year. The unwind of this whale’s portfolio suggests that recovery for affected Ai agent tokens may be slow, particularly if confidence among large investors remains fragile.

Implications beyond Ai agent tokens

Beyond the immediate losses, the liquidation raises strategic questions for the crypto industry. Projects tied to Ai agent tokens often market innovation and automation, but the episode shows that basic market structure — liquidity depth, distribution of ownership, and exit pathways — remains critical.

Tags: agentAIblockchaincryptodefiliquiditymarketstokensVirtualswhale
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Moses Edozie

Moses Edozie

Moses Edozie is a writer and storyteller with a deep interest in cryptocurrency, blockchain innovation, and Web3 culture. Passionate about DeFi, NFTs, and the societal impact of decentralized systems, he creates clear, engaging narratives that connect complex technologies to everyday life.

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Wyoming Crypto Bank Petition Challenges Fed’s Master Account Authority At the heart of the Wyoming Crypto Bank petition is the Federal Reserve’s refusal to grant Custodia access to a master account—an essential gateway to core payment rails such as wire transfers and automated clearinghouse (ACH) services. Without it, Custodia says its Wyoming-issued charter is effectively rendered meaningless. Custodia contends the ruling conflicts directly with the Monetary Control Act (MCA), which states that Federal Reserve services shall be available to nonmember depository institutions. The bank argues the Fed has transformed that mandate into what it calls an unconstitutional veto over state banking decisions. When the Fed denies a master account to a state-chartered financial institution, it effectively vetoes a bank charter that State regulators have approved, Custodia wrote in its petition. State Banking Authority Under Threat The Wyoming Crypto Bank petition also raises serious federalism concerns. Wyoming chartered Custodia in 2020 as a Special Purpose Depository Institution (SPDI), a regulatory framework specifically designed to attract digital asset firms while minimizing systemic risk through 100% reserve backing and a prohibition on lending. Custodia argues the Fed’s rejection undermines Wyoming’s carefully constructed regulatory regime and erodes states’ constitutional authority to charter banks. The petition warns that allowing the Fed such power could discourage innovation-driven state banking models nationwide. Constitutional Red Flags in the Wyoming Crypto Bank Petition Beyond federalism, the Wyoming Crypto Bank petition pushes into constitutional territory. Custodia’s legal team argues that if regional Federal Reserve Bank presidents possess unreviewable discretion over master accounts, they effectively function as “Officers of the United States” without proper constitutional appointment. Federal Reserve Bank presidents are selected by private bank directors and approved by the Board of Governors. Custodia says that structure violates the Appointments Clause if those officials wield significant executive authority. Judicial Split Deepens Over Wyoming Crypto Bank Petition The petition highlights a growing divide within the Tenth Circuit itself. Judge Timothy Tymkovich’s dissent in Custodia’s case aligns with Judge Robert Bacharach’s earlier opinion in Fourth Corner Credit Union v. Federal Reserve Bank of Kansas City, creating a 2-2 split among circuit judges. Tymkovich warned that the Fed’s interpretation grants “unreviewable discretion” that contradicts the plain language of the MCA and raises “thorny questions” under Article II of the Constitution. Fed’s Own Records Undermine Denial Rationale The Wyoming Crypto Bank petition also points to contradictions within the Federal Reserve’s own process. The Kansas City Fed denied Custodia’s application in January 2023 after a 27-month review, citing risks tied to “crypto-asset activities.” Yet internal documents show Fed staff initially found Custodia’s capital levels “adequate” and praised its leadership as “impressive.” Custodia says the decision only shifted after intervention by the Board of Governors. Federal Reserve Governor Christopher Waller later acknowledged publicly that the Fed has sufficient supervisory tools to manage risk without blanket denials. In an October interview, Waller said the Fed can “tailor” master account structures to fit a bank’s specific risk profile. Wyoming Crypto Bank Petition Lands Amid Crypto Debanking Reckoning The Wyoming Crypto Bank petition arrives as regulators face mounting scrutiny over crypto debanking. In December, the Office of the Comptroller of the Currency revealed that all nine of the largest U.S. banks imposed “inappropriate” restrictions on lawful businesses, including digital asset firms, between 2020 and 2023. Institutions such as JPMorgan Chase, Bank of America, Citibank, and Wells Fargo maintained internal policies that escalated or restricted entire sectors, reinforcing claims of systemic exclusion. If the full Tenth Circuit agrees to hear the Wyoming Crypto Bank petition, the outcome could redefine the balance of power between state banking regulators and the Federal Reserve—setting a precedent that reaches far beyond Custodia and Wyoming. For the crypto industry, the case may determine whether compliance-focused digital asset banks can ever gain equal footing within the U.S. financial system.Wyoming Crypto Bank Petition Sparks High-Stakes Legal Showdown as Fed Power Faces Fierce Constitutional Test

Wyoming-chartered Custodia Bank challenges Federal Reserve’s master account veto power

12/16/2025
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