In March 2025, U.S. President Donald Trump signed an executive order to create a Bitcoin reserve. The industry welcomed this decision, anticipating government purchases of the first cryptocurrency and a new source of demand in the market.
In this context, the topic began to be discussed in other countries. Some spoke of creating strategic funds and transforming the global financial system, while others criticized the approach. However, it soon became clear that the American strategic Bitcoin reserve was structured quite differently than the market had expected.
ForkLog investigated which countries are genuinely integrating digital assets into their reserve policies and which have not progressed beyond discussions.
A Bold Promise
In the spring of 2025, the idea of a state cryptocurrency reserve sounded like a potential turning point not only for the industry but also for the global financial system. On March 2, Trump announced that a working group should expedite the creation of a "strategic reserve of digital assets." The list included five coins: BTC, ETH, SOL, XRP, and ADA.
The market reacted positively, with participants hoping for not just recognition of Bitcoin at the state level but also potential purchases by the world's largest economy. The inclusion of altcoins in the list was also seen as a positive sign.
However, it soon became apparent that the initiative was gradually losing relevance. At the crypto summit in the White House, the administration indicated that it was focusing solely on Bitcoin. Commerce Secretary Howard Lutnick stated that this currency would be considered separately from other digital assets.
What Trump Actually Signed
The executive order outlined the project's real contours. It divided the initiative into two directions: the "Strategic Bitcoin Reserve" (SBR) and a "Digital Asset Reserve" intended for other coins.
A significant nuance was where the funds would be sourced. They were not to be filled through regular budget purchases but rather from assets seized in criminal and civil cases. Former Trump advisor on AI and cryptocurrencies David Sacks emphasized that the project "will not cost taxpayers a cent."
As a result, instead of creating new demand, the government reclassified confiscated assets as long-term investments.
The administration's position was ultimately clarified by Treasury Secretary Scott Bessent. The strategy boiled down to three points:
- not to purchase Bitcoin with government funds;
- to retain already accumulated coins;
- to replenish the reserve with assets seized in legal proceedings.
Later, Bessent added that the department was exploring "budget-neutral" ways to expand the reserve, but no specific mechanism was presented.
The most ambitious scenario remained in the Senate. On March 11, 2025, Cynthia Lummis introduced an updated Bitcoin Act. The bill proposed purchasing up to 200,000 BTC per year over five years to increase the reserve to 1 million coins and lock them away for 20 years. The document did not receive support in Congress.
By 2026, it became clear that even the basic structure had stalled. In July, Bloomberg reported that the work on the SBR was being hampered by disagreements among federal agencies. Although the order assigned management of the reserve to the Treasury Department, officials began to question whether the agency had the necessary expertise to manage such a specific asset. Other potential departments mentioned for managing the reserve included the Department of Commerce and the Department of Justice. The White House continued to search for an optimal management structure.
Simultaneously, efforts were made to enshrine the idea in law. In May, the American Reserve Modernization Act (ARMA) was introduced in the House of Representatives. The document assigns the reserve to the Treasury, mandates agencies to centrally send coins for storage, introduces quarterly reports, independent audits, and Congressional oversight. Bitcoin is proposed to be held for at least 20 years and sold only to reduce national debt. The target of 1 million BTC, as in the Bitcoin Act, is no longer included in ARMA.
According to BitcoinTreasuries, at the time of writing, the U.S. held the top position among countries with 328,372 BTC.
Source: BitcoinTreasuries.The Kazakh Approach
Other countries are also attempting to implement digital asset fund projects. One example is Kazakhstan, where a National Strategic Crypto Reserve is being formed at the president's directive. Authorities estimate its volume could eventually reach $700 million.
Sources for replenishment are outlined in advance. Up to $350 million could come from investing part of the National Bank's gold and foreign currency assets, with another $350 million from the National Fund's assets. Additionally, the reserve aims to include other state assets at the government's discretion, including confiscated cryptocurrencies. This scheme is similar to the American model of "no burden on taxpayers," but it is supplemented by a plan for active investments rather than mere storage.
The reserve will be managed by the National Investment Corporation of the National Bank, while the Central Securities Depository will handle the accounting and storage of digital assets. The assets are planned to be directed towards digital coins, derivative instruments based on them, as well as stocks and shares of companies developing this sector. Investments through hedge funds are also being explored.
The reserve has become part of a broader strategy. In July, President Kassym-Jomart Tokayev signed a decree "On Measures to Stimulate and Develop the Digital Asset Industry." The document sets the framework for the entire sector: using cryptocurrencies and stablecoins in cross-border settlements, bringing operations into the legal field through voluntary asset disclosure from foreign platforms, and transferring them to domestic providers.
This institutional clarity distinguishes the Kazakh approach from the American one. The reserve has an owner, a manager, a custodian, sources of replenishment, an investment plan, and mandatory annual reporting, and it is integrated into the overall strategy for industry development.
Who Else is in the Game
The topic of national crypto reserves has attracted interest not only from the U.S. and Kazakhstan. According to BitcoinTreasuries, governments collectively hold about 649,961 BTC—approximately 3.1% of the total supply.
Source: BitcoinTreasuries.Some positions are the result of confiscations rather than deliberate reserve policies. Therefore, government approaches to Bitcoin can be divided into several scenarios:
- Accumulation through seizures. This path is taken by the U.S. and partially Kazakhstan: the reserve is primarily composed of Bitcoins obtained this way rather than market purchases. The advantage of this approach is the absence of budgetary expenses. The downside is that the reserve depends on law enforcement actions, court decisions, and the movement of these coins.
- Mixed approach. Kazakhstan has some sources linked to state assets and investments, while part comes from confiscated assets.
- Direct purchases. The most well-known example is El Salvador. The country has been gradually purchasing Bitcoin in small batches and publicly displaying its balance. This approach is controversial in terms of risks but clear in terms of transparency: it shows how much and at what price coins were purchased.
- Reserve through mining. Bhutan follows this method. The state uses excess hydroelectric power to mine Bitcoin and has accumulated a notable reserve relative to the size of its economy.
- Discussion without action. This category includes most countries. Central banks and ministries have considered the idea of holding part of their reserves in the first cryptocurrency, but it has not progressed beyond statements and analytical notes. For example, the head of the Czech National Bank, Aleš Michl, publicly allowed for the study of digital gold as a reserve asset—without moving to purchases.
At the state level in the U.S., the picture is also mixed. Some have passed laws regarding their own Bitcoin reserves, while others have rejected similar initiatives. A unified federal approach to purchases has yet to emerge.
As a result, the pioneers of the strategic crypto reserve have not been able to demonstrate how it should work in practice. Their model currently resembles a new method of storing confiscated coins rather than a full-fledged tool of state financial policy.
A Reserve Without an Answer to "Why"
The problems of the American SBR are not limited to a lack of infrastructure. Any classic reserve has a function: oil reserves smooth out shocks, currency reserves ensure financial stability. The U.S. Bitcoin reserve lacks such a role—coins cannot be spent, they do not back the dollar, and they do not solve any problems. There is no consensus in the country on whether to consider the coin a sovereign asset worth budgetary funds.
It is telling that the state that made the loudest claims about creating a crypto reserve has set an example of inaction, while those who act more quietly are shaping the practice. Kazakhstan has outlined a plan, El Salvador is buying Bitcoin and showing its balance, and Bhutan is mining it using its hydroelectric power.
The conclusion is that the size of the reserve does not indicate its significance. The U.S. holds the most Bitcoins and is the furthest from a functioning tool because there is neither a goal nor a mechanism behind the number. Until there is an answer, any crypto reserve remains on paper.