PANews reported on December 16 that, according to crypto journalist Eleanor Terrett, Wyoming-based crypto bank Custodia Bank has filed for a full review, meaning the bank is requesting a review of its October ruling by the entire Tenth Circuit Court of Appeals (rather than the initial panel of three judges) that upheld the Federal Reserve's decision to deny Custodia Bank the right to open a master account.

The application argues that the original trial panel misunderstood the Currency Control Act, which allows any qualified bank to open a master account; the panel's actions weakened state banking oversight and raised serious constitutional issues.