On December 17, 2024, U.S. time, Trump announced that he had secured enough electoral votes in the state electoral college meetings to officially win the presidency. Next, Trump and his vice president Vance will be sworn in on January 20, 2025. This news is undoubtedly a "stabilizing force" for the U.S. crypto community, and it is foreseeable that a prosperous era of cryptocurrency in the U.S. is about to arrive.
So, what will be the next crypto-friendly actions from the Trump team? The first thought that comes to mind is the "BTC Strategic Reserve Proposal."
Whether during the campaign or recently, Trump has repeatedly mentioned the Bitcoin strategic reserve. The latest news indicates that Trump is considering using the U.S. Treasury's Exchange Stabilization Fund to establish a Strategic Bitcoin Reserve (SBR) after his inauguration; additionally, the U.S. Bitcoin Policy Institute (a non-partisan nonprofit organization) has already drafted this executive order, which only needs Trump's signature to take effect after he is sworn in.
In addition to the "White House candidate," some U.S. states have also begun to take frequent actions regarding Bitcoin reserves. Several states, including Texas and Pennsylvania, have proposed specific bills to support fiscal stability by accepting Bitcoin tax payments or establishing local Bitcoin reserves. These initiatives signify that the U.S. is paving the way for the practical operation of Bitcoin reserves, and the arrival of Trump's new government will inject stronger momentum into this process.
International Trends of BTC Strategic Reserves
The U.S. push for Bitcoin reserves not only changes its domestic cryptocurrency policy landscape but also sparks a global competition for Bitcoin strategic reserves. While attitudes toward this emerging asset vary among governments and regions, there is a gradual deepening of scrutiny regarding Bitcoin's potential.
In Latin America, El Salvador remains the "pioneer" of global Bitcoin reserves. Since announcing Bitcoin as legal tender in 2021, El Salvador has continued to accumulate Bitcoin reserves. The latest data shows that El Salvador's Bitcoin holdings have surpassed 5,950 BTC. Recently, Brazil has been closely following El Salvador's lead, exploring the establishment of a Bitcoin strategic reserve. In November 2024, Brazilian federal deputy Eros Biondini proposed a bill to establish a plan called "Bitcoin Sovereign Strategic Reserve" (RESBit), aiming to include Bitcoin in the country's international reserves by 5%.
In Europe, Poland's Bitcoin strategic reserve proposal has attracted significant attention. Polish presidential candidate Sławomir Mentzen has publicly advocated for including Bitcoin in the national reserve system and plans to attract more investors through crypto-friendly regulations and tax policies. Although no specific policy has been formed yet, discussions in Poland have sparked interest in Bitcoin reserves across Europe.
In contrast, the attitude in Asia appears more cautious. According to current media reports, aside from Japan, no other countries or regions have made official statements about including Bitcoin in their national strategic reserves. In Japan, discussions about government Bitcoin reserves have just begun. Legislator Akira Hamada submitted a formal request to the Japanese parliament in December, drawing significant attention from the Japanese crypto community.
However, this competition for Bitcoin reserves is not limited to the national level. Enterprises and financial institutions have also begun to enter the Bitcoin reserve arena, becoming a driving force behind the rise of Bitcoin and the overall crypto market.
Global Enterprises and Institutions Entering the Market
Data shows that 144 companies currently hold Bitcoin. In fact, corporate holdings of Bitcoin are not new this year.
As early as 2020, MicroStrategy, an American company, began to continuously increase its Bitcoin holdings. As of December 16, the company held 439,000 BTC, with an average purchase price of $61,725 per Bitcoin. This means that MicroStrategy's current Bitcoin profits exceed $20 billion. This remarkable achievement has made MicroStrategy a "leader" in corporate Bitcoin investment, and its buying and holding strategy has provided a reference for other traditional companies exploring digital asset reserves. In addition to MicroStrategy, crypto-friendly companies like Tesla and Block (formerly Square) have also joined this trend, diversifying their assets and hedging against inflation through Bitcoin allocation.
Fast forward to this year, more companies globally have begun to establish Bitcoin investment plans. For example, Canadian company Jiva Technologies recently announced plans to purchase $1 million worth of Bitcoin as part of its financial strategy; U.S. company Marathon Digital announced an additional $1.1 billion in Bitcoin; and Japanese company Metaplanet plans to increase its holdings to 10,000 Bitcoins by 2025.
At the same time, traditional financial institutions, represented by BTC spot ETFs, are also increasing their investments in Bitcoin. According to SoSoValue data from December 18, the total net inflow of Bitcoin spot ETFs reached $494 million the previous day, marking 14 consecutive days of net inflow.
In this global competition, Hong Kong, as a financial center in Asia, has not yet seen any government-level involvement, but enterprises have already rushed into the market. For instance, Hong Kong-listed company Boyaa Interactive (HK.0403) announced it holds 2,641 Bitcoins and subsequently exchanged for 515 more, bringing its holdings to over 3,000; Nasdaq-listed company Nano Labs recently announced plans to invest $50 million in BTC asset allocation. Previously, listed companies such as Guofu Innovation and Coolpad Group had also begun to allocate Bitcoin early on.
In contrast, mainland Chinese enterprises have made very few moves regarding Bitcoin reserves. The only one, Hua Bao Overseas Technology (QDII-FOF-LOF) C, holds BTC ETFs through indirect investment. Subsequently, possibly due to extensive media exposure, the fund announced it would suspend this indirect investment.
Such a stark difference is primarily due to the uncertainty of Chinese policies and compliance risks. Since China comprehensively banned cryptocurrency-related commercial activities in 2021, direct participation in Bitcoin reserves by enterprises faces numerous obstacles in terms of security and legal compliance. So, is there a solution?
Investment Strategies of Overseas Crypto Funds
Although mainland policies impose many restrictions on directly holding Bitcoin, this does not mean that mainland enterprises are completely excluded from the Bitcoin reserve competition. In fact, by establishing offshore funds in Hong Kong or leveraging compliant overseas crypto funds, mainland enterprises may find a legitimate path to participate in this global competition.
In the past two years, Hong Kong has gradually established a comprehensive compliance framework for virtual assets by implementing a Virtual Asset Service Provider (VASP) licensing system and has begun to relax strict restrictions on the virtual asset industry. Against this backdrop, mainland enterprises can choose to set up offshore funds in Hong Kong and entrust licensed digital asset management institutions for asset allocation, thereby achieving compliant Bitcoin holdings. This model not only complies with legal regulations but also leverages Hong Kong's policy advantages to prepare for potential future policy relaxations.
In addition to the Hong Kong market, mature overseas crypto funds also represent a viable path. For example, Grayscale Bitcoin Trust provides a compliant Bitcoin investment method for institutional investors through a trust structure. This approach can effectively avoid the policy risks associated with directly holding Bitcoin. However, if mainland enterprises wish to participate in similar investments, they need to establish compliant entities abroad and operate through Hong Kong or other offshore jurisdictions to ensure the legality of the source and use of funds. Similarly, this path not only resolves legal entity issues but also offers greater operational flexibility.
Moreover, in recent years, traditional financial institutions, including Fidelity and BlackRock, have launched Bitcoin spot ETFs and other crypto asset investment products. These funds provide institutional investors with transparent and legal ways to hold Bitcoin, offering more options for mainland enterprises to invest through offshore entities. However, this model also needs to address the compliance issues related to the outflow of funds. Cross-border capital flows must strictly adhere to China's foreign exchange management policies and ensure transparency in the source and use of funds.
Summary by Mankun Law Firm
The significance of Bitcoin reserves has long transcended asset allocation itself; it is becoming an important piece in the global digital economy strategy. The Trump administration's push for Bitcoin reserves not only ignites a global digital asset competition but also brings new opportunities for enterprises to seek new directions in the wave of the digital economy. However, for Chinese enterprises, policy restrictions and regulatory risks undoubtedly pose a threshold that requires cautious handling.
By establishing offshore crypto funds in Hong Kong or investing in regulated overseas mature crypto funds, Chinese enterprises can still find breakthroughs in this global competition within the boundaries allowed by policy, gaining more initiative for future digital economy layouts. However, this process must strictly adhere to legal and compliance boundaries.
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