On July 25, 2025, the Internal Revenue Service (IRS or Service) released an Interim Guidance Memorandum dated July 23, 2025 (the IGM) that i) eliminates the Acknowledgement of Facts (AOF) Information Document Requests (IDR) from Large Business & International Division (LB&I) examinations, ii) provides updates on the changes to the Fast Track Settlements (FTS) pilot program, and iii) clarifies the applicability of Accelerated Issue Resolution (AIR) to Large Corporate Compliance (LCC) cases.

As federal antitrust enforcement continues to evolve, adjust priorities, and in some cases, stall out, states are increasingly enhancing their enforcement focus, resources, and law.

In this alert, Winston’s Financial Innovation & Regulation Practice takes a closer look at the recent joint statement by the Office of the Comptroller of the Currency (OCC), the Federal Reserve Board (FRB), and the Federal Deposit Insurance Corporation (FDIC) regarding the safekeeping of crypto-assets and implications for the financial services industry.

The OCC, FRB, and FDIC have issued a joint statement clarifying the regulatory expectations applicable to the safekeeping of crypto-assets by banking organizations. The interagency statement offers a structured articulation of how legacy supervisory principles are expected to operate in the emerging context of crypto-asset safekeeping by banking organizations.