The US regulatory approach to digital assets took two significant steps this week, as the Office of the Comptroller of the Currency (OCC) clarified how banks can hold crypto for blockchain network fees while the White House advanced an Internal Revenue Service (IRS) proposal to widen oversight of international crypto transactions. The moves signal deeper integration of digital assets into mainstream banking, alongside tighter tax reporting standards.
The OCC issued Interpretive Letter 1186, confirming that national banks may hold crypto assets on their own balance sheets when they need those assets to pay blockchain “gas fees” for otherwise permissible activities. The guidance applies to fees on public networks and to tokens required for testing crypto-related platforms developed in-house or acquired from third parties.
Under the new guidance, a bank can maintain only the amount of digital assets it reasonably expects to need for operations, and it must manage those holdings under existing safety and soundness standards. The OCC stressed that banks must follow applicable law, including risk management rules and customer protection requirements, when they use crypto to process transactions or support custody services.
The clarification sits within the framework of the Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act, which created a federal regime for payment stablecoins earlier this year. The law established licensing, reserve, and compliance standards for dollar-pegged stablecoins and positioned the OCC as a central supervisor for bank-issued tokens and related infrastructure.
The White House is also reviewing an IRS rule that would give the agency access to information on US taxpayers’ digital asset activity conducted through foreign platforms. The proposal, received by the Office of Information and Regulatory Affairs, aims to align US rules with the global Crypto-Asset Reporting Framework (CARF), an initiative led by the OECD to share cross-border crypto data and curb tax evasion.
If adopted, the “Broker Digital Transaction Reporting” rule would pull the United States into a network of more than 70 countries that plan to implement CARF by 2027- 2028. Foreign exchanges and service providers handling US customers would need to report specified transactions, making it harder for taxpayers to hide offshore holdings by shifting assets between jurisdictions.
The push builds on a July White House report that argued CARF adoption would discourage Americans from moving digital assets to lightly regulated overseas platforms and would reduce competitive gaps between US exchanges and offshore rivals. The same report indicated that DeFi transactions should not face new reporting duties under the framework, though authorities continue to monitor that segment.
For domestic markets, the IRS already finalized regulations that require brokers to report digital asset sales and exchanges on the new Form 1099-DA, with phased duties starting from transactions in 2025 and expanded basis reporting in 2026.
Platforms such as custodial exchanges, certain wallet providers, and payment processors will need to send those forms both to customers and to the IRS, increasing transparency around gains and losses from crypto activity.
The OCC gas-fee guidance and the IRS reporting agenda frame a dual track for US crypto policy: banks receive clearer authority to use and hold tokens in day-to-day operations, while regulators tighten oversight of how taxpayers move and report digital assets at home and abroad.
Banks that adopt blockchain for payments or custody must now balance new operational flexibility with stricter expectations around tax reporting, documentation, and cross-border information sharing.
For crypto users, the combination of CARF alignment and 1099-DA reporting points toward a future where offshore accounts and on-chain transfers sit under far closer scrutiny. As rules take effect over the next several years, both institutions and individuals will need to update compliance systems and record-keeping to match a more data-driven approach to digital asset regulation.
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