In the wake of President Trump’s Executive Order on March 6, which established a Strategic Bitcoin Reserve and a U.S. Digital Asset Stockpile, federal agencies and market stakeholders are beginning to confront the operational and compliance ramifications of the government’s proposed entry into cryptocurrency ownership and management. Although many specifics of the initiative are still being developed, it introduces critical questions concerning governance, custody, disclosure, and compliance with existing financial and national security regulations.
As the U.S. shifts its perspective to view digital assets as integral components of sovereign infrastructure rather than mere speculative tools, various compliance responsibilities—some already in place and others on the horizon—will need to be addressed.
Asset Classification and Oversight
Agencies responsible for overseeing cryptocurrency markets, such as the SEC, CFTC, FinCEN, and the IRS, will likely need to collaborate with the Presidential Working Group on Digital Asset Markets (previously addressed here), which the executive order highlights as a crucial platform for establishing operational standards for the reserve. This collaboration could encompass initiatives such as: (i) formulating inter-agency compliance protocols for classifying and managing various digital assets, and (ii) determining if government ownership triggers obligations under current securities, commodities, or money transmission laws when assets are transferred, staked, or utilized in decentralized finance protocols to yield returns.
Custody, Security, and Risk Controls
Currently, federal crypto assets are managed under a diverse array of custody arrangements, frequently involving third-party custodians appointed by the DOJ and U.S. Marshals Service (previously mentioned here). The strategic reserve initiative may catalyze the formalization and regulation of public-sector crypto custody, which might include:
- Deployment of multi-signature wallets and tiered access controls;
- Separate asset storage across agencies or central consolidation under one federal custodian;
- Audit processes to validate the provenance and security of network hardware utilized to hold and manage the digital asset reserve;
- Required internal controls and regular audits of wallet operations, private key management, and access logs.
Anti-Money Laundering, Sanctions, and Forfeiture Frameworks
As the federal government broadens its holdings in digital assets, it must ensure strict compliance with anti-money laundering (AML) and sanctions regulations for both strategically acquired and seized assets. This compliance may involve:
- Screening assets and counterparties for any ties to OFAC-sanctioned jurisdictions or wallet addresses;
- Formulating procedures for chain-of-custody documentation in asset procurement or liquidation;
- Assessing whether assets obtained through strategic procurement (as opposed to seizure linked to illegal activities) necessitate new reporting or risk management protocols under the Bank Secrecy Act and Patriot Act.
Moreover, if the Digital Asset Stockpile includes tokens utilized in DeFi protocols or for cross-border settlements, there will be additional considerations regarding the government’s obligations to adhere to evolving international AML and counter-terrorism financing standards.
Putting It Into Practice
The establishment of a Strategic Bitcoin Reserve and Digital Asset Stockpile signifies a profound shift in how the federal government interacts with cryptocurrency assets—not just as a regulator, but now also as a market participant, custodian, and price influencer. As this strategy develops, the agencies and contractors tasked with its implementation will need to create robust compliance frameworks aligned with existing financial regulations, agency protocols, and national security aims.
