Treasury Is Building a Bitcoin Custody Framework as Estimates of Federal Holdings Range From 198,000 to 328,000 BTC

Treasury is building a custody framework for the Bitcoin the federal government holds. It may combine self-custody, where the government holds its own private keys, with outside custodians that hold keys on its behalf.

The details come from Patrick Witt, the former executive director of the White House crypto council, who discussed the policy in a What Bitcoin Did interview on Nov. 9. His remarks were relayed again on Nov. 11.

A stash nobody has put a number on

The Strategic Bitcoin Reserve was created on March 6, 2025, by Executive Order 14233. It is built mostly from coins the government acquired through civil and criminal forfeitures, not from open-market purchases.

The order lets Treasury manage those coins and bars routine sales, with exceptions only in limited circumstances.

How much is in there is unsettled. Estimates run from roughly 198,000 BTC to more than 328,000 BTC. The spread largely comes down to whether coins tied up in pending litigation are counted.

Witt did not give a total in the interview. He said agency holdings are going through a second round of verification to improve the accuracy of the data. The original order gave agencies 30 days to review and report what Bitcoin they controlled.

Witt said it has not been decided whether specific holdings will be made public. He also described the scope question as hard: whether intelligence agencies and undisclosed activities belong in the count. Publicly operating agencies, he said, gave reasonably useful answers to information requests, though quality varied.

Cold wallets in drawers

Witt was blunt about the state of custody inside government. Practices varied widely across agencies, he said. Some kept cold wallets in drawers. Others handed assets to outside custodians.

He cited allegations involving the U.S. Marshals that a contractor's son stole digital assets, and called the custody practices unacceptable. Those are allegations as Witt described them.

The framework is aimed at operational custody. It is not framed as a response to any outside breach, though the industry has been paying closer attention to cold wallet security after recent firmware issues in hardware wallets.

The sales question

Witt said the executive order stopped government cryptocurrency sales. He described some disposals under the previous administration as resembling fire sales and argued that holding those coins would have preserved considerable value on the government's balance sheet.

He declined to give specific examples. He also acknowledged he had no evidence anyone intended to push prices lower, and said some of the sales simply looked unsophisticated.

That is a judgment from a current-policy figure about his predecessors' decisions, offered without named cases. The no-sales rule it supports is already in the executive order.

Buying more is only a discussion

Witt said Treasury has discussed several ways to acquire Bitcoin: revaluing gold reserves, using the Exchange Stabilization Fund, converting other assets, and collecting taxes and fees in Bitcoin.

All of them need further legal analysis. They are discussions, not adopted rules, and Witt said there is no consensus yet. The reserve today is a forfeiture pile, and any expansion would need a legal foundation that is still being studied.

Separately, no one will be appointed executive director of the White House Crypto Council. Its duties will be shared by the White House Office of Legislative Affairs, the White House Counsel's Office, and other departments.

Agencies move while Congress stalls

The Digital Asset Market Clarity Act fell short of the 60 votes needed to advance in the Senate on Sept. 15, 2026. Witt said Bitcoin does not depend on its passage because its status as an asset outside securities regulation is broadly accepted. He added that the bill could have helped integrate crypto with the financial system and reduced industry uncertainty.

He blamed political division. Technology has become a partisan issue, Witt said, and he questioned whether Democrats would back legislation widely seen as a Republican priority.

With the bill stalled, agencies have kept working under existing authority. On Oct. 1, 2026, the SEC proposed custody rule changes for investment advisers and regulated funds. The proposal would allow self-custody under specified safeguards, or custody with a state-chartered trust company that meets defined standards. SEC Chairman Paul Atkins described it as closing a gap that left market participants without clear, compliant options.

That proposal covers private-sector advisers and funds, not the federal reserve. But the two-track structure, self-custody or a qualified third party, is the same one Treasury is weighing for its own coins.

What comes next

The open items are concrete. Treasury has not said whether it will publish its holdings, or when the custody framework will be finalized. Until agencies settle on a reliable count, the range of roughly 198,000 BTC to more than 328,000 BTC will keep circulating, with pending litigation driving much of the uncertainty.