Treasury Cryptocurrency Holdings and Management

Jordan Lassiter
Investigative Journalist
March 12, 2025

Records Access Officer
Freedom of Information Act Request
U.S. Department of the Treasury
1500 Pennsylvania Avenue, NW
Washington, DC 20220

**DISCLAIMER:**
Please read this FOIA request carefully. All communications regarding this request are public and may be disclosed on the MuckRock platform.

FREEDOM OF INFORMATION ACT REQUEST - TREASURY CRYPTOCURRENCY HOLDINGS AND MANAGEMENT

Dear FOIA Officer:

Pursuant to the Freedom of Information Act (5 U.S.C. § 552 et seq.) and Treasury Department FOIA regulations (31 C.F.R. Part 1), I, Jordan Lassiter, hereby request access to all records and documents pertaining to the U.S. Department of the Treasury's cryptocurrency holdings, transactions, and management protocols. This request encompasses, but is not expressly limited to, the categories of records delineated below.

1. DIGITAL WALLET ADDRESSES AND HOLDINGS:

A comprehensive and detailed inventory of all digital wallet addresses held, managed, controlled, or monitored by the Department, its offices, bureaus, and authorized agents, including:

a) **Wallet Infrastructure Details:**
- Public wallet addresses with corresponding blockchain identifiers
- Security protocols implemented for wallet access and management
- Multi-signature authorization structures and associated key management systems
- Cold storage vs. hot wallet distribution ratios and security implementation details
- Hardware security modules (HSMs) utilized for private key protection

b) **Cryptocurrency Holdings Inventory:**
- **Layer-1 Blockchain Assets:** Bitcoin (BTC), Ethereum (ETH), Binance Coin (BNB), Cardano (ADA), Solana (SOL), Avalanche (AVAX), Polkadot (DOT), Cosmos (ATOM), Bitcoin Cash (BCH), Litecoin (LTC)
- **Privacy-Focused Cryptocurrencies:** Monero (XMR), Zcash (ZEC), Dash (DASH), Firo (FIRO), Zcoin (XZC), Grin (GRIN), Beam (BEAM)
- **Stablecoins:** Tether (USDT), USD Coin (USDC), Dai (DAI), TrueUSD (TUSD), Binance USD (BUSD), Pax Dollar (USDP)
- **DeFi & Utility Tokens:** Uniswap (UNI), Chainlink (LINK), Aave (AAVE), Compound (COMP), Maker (MKR), Yearn.Finance (YFI)
- **Alternative Cryptocurrencies:** Dogecoin (DOGE), Shiba Inu (SHIB), Ripple (XRP), Stellar (XLM), EOS.IO (EOS), Tron (TRX), Algorand (ALGO), BitClout (CLOUT), SafeMoon (SAFEMOON), Namecoin (NMC), Peercoin (PPC), Gridcoin (GRC), Primecoin (XPM), Vertcoin (VTC), Ethereum Classic (ETC)
- **Non-Fungible Tokens (NFTs):** Any and all NFTs held by the Department, including collection names, token IDs, and associated metadata

c) **Transaction Records:**
- Comprehensive transaction histories for each wallet address, including:
- Transaction hashes
- Block heights and timestamps
- Transaction amounts and fees
- Counterparty addresses
- Transaction purposes (categorized by operational objective)
- Authorization records for each transaction
- Internal accounting codes and classifications for each transaction

2. RECORDS OF SEIZED OR FORFEITED DIGITAL ASSETS:

a) **Asset Forfeiture Documentation:**
- All records, reports, and associated documentation relating to cryptocurrency assets seized, frozen, or forfeited through criminal or civil proceedings
- Case identifiers for each seizure event, including court dockets and agency reference numbers
- Chain of custody documentation for seized digital assets
- Technical details of seizure methodologies employed

b) **Legal Basis and Processing:**
- Documentation detailing the specific legal authorities relied upon for each seizure
- Court orders, warrants, and associated legal filings authorizing the seizure of digital assets
- Records of administrative and judicial proceedings related to cryptocurrency forfeitures
- Documentation of due process notifications provided to affected parties

c) **Valuation and Accounting:**
- Methodology used to determine the USD value of seized assets at time of seizure
- Accounting records showing how seized assets are recorded on Treasury's books
- Valuation reassessments and marked-to-market accounting records
- Revenue recognition protocols for seized assets

d) **Strategic Bitcoin Reserve and U.S. Digital Asset Stockpile:**
- Complete inventory of assets allocated to the Strategic Bitcoin Reserve
- Allocation criteria and distribution methodology for assets directed to the U.S. Digital Asset Stockpile
- Governance structures established for management of these reserves
- Risk management frameworks implemented for these holdings
- Accounting treatment and financial reporting standards applied to these reserve assets

3. INTERNAL POLICIES AND INTERAGENCY COMMUNICATIONS:

a) **Operational Policies and Procedures:**
- All internal directives, memoranda, handbooks, manuals, and standard operating procedures regarding:
- Acquisition of digital assets
- Secure storage protocols
- Transaction approval processes
- Key management and access controls
- Asset disposition guidelines
- Audit and compliance requirements

b) **Strategic Planning Documents:**
- Long-term strategy documents related to digital asset holdings
- Risk assessment frameworks for cryptocurrency portfolios
- Contingency planning for blockchain forks, security vulnerabilities, or regulatory changes
- Economic analysis of Treasury cryptocurrency holdings and their potential impact on markets

c) **Interagency Communications:**
- All communications, meeting minutes, memoranda of understanding, and joint operation agreements between the Treasury Department and:
- Department of Justice (including FBI and U.S. Marshals Service)
- Securities and Exchange Commission
- Commodity Futures Trading Commission
- Financial Crimes Enforcement Network (FinCEN)
- Office of Foreign Assets Control (OFAC)
- Internal Revenue Service
- Department of Homeland Security
- Federal Reserve System
- Office of the Comptroller of the Currency
- Secret Service

- Specifically including communications regarding:
- Coordination of digital asset seizures
- Transfer protocols between agencies
- Joint custody arrangements
- Implementation of Executive Order 14178
- Establishment of the Strategic Bitcoin Reserve
- Development of the U.S. Digital Asset Stockpile

- For all email communications responsive to this request, please include complete metadata, including but not limited to:
- Full email headers
- BCC recipients
- Timestamps and time zones
- Email chain histories
- Delivery and read receipts
- Server routing information
- Message IDs
- IP addresses of senders and recipients
- All attachments in their native format with intact metadata

4. IMPLEMENTATION DOCUMENTATION FOR THE STRATEGIC BITCOIN RESERVE AND DIGITAL ASSET STOCKPILE:

a) **Executive Order Implementation:**
- All records, reports, action plans, and internal guidance documents created to implement Executive Order 14178
- Working group or task force formation documents, including membership rosters and meeting minutes
- Implementation timelines, milestones, and progress reports
- Budget allocations and resource commitments for implementation activities

b) **Operational Infrastructure:**
- Technical specifications for storage systems used for the Strategic Bitcoin Reserve
- Security protocols and vulnerability assessments for reserve storage systems
- Documentation of physical security measures for cold storage components
- Redundancy and disaster recovery plans for the reserve infrastructure

c) **Governance Framework:**
- Decision-making authority documentation for reserve management
- Oversight committee charters and membership
- Conflict of interest policies for officials with access to reserve assets
- Audit schedules and methodologies for reserve verification

d) **Financial and Economic Analysis:**
- Market impact assessments of reserve establishment and operations
- Economic models used to determine optimal reserve size and composition
- Valuation methodologies for reserve assets
- Long-term projections and scenario analyses for reserve management

e) **Public Communication Materials:**
- Drafts and final versions of press releases, fact sheets, and other public communications regarding the Strategic Bitcoin Reserve and U.S. Digital Asset Stockpile
- Talking points prepared for officials regarding these initiatives
- Records of congressional briefings or testimony regarding these programs

5. EXTERNAL CONTRACTS AND VENDOR RELATIONSHIPS:

a) **Custodial Services:**
- All contracts, statements of work, and service level agreements with third-party cryptocurrency custodians
- Vendor selection criteria and evaluation documents
- Due diligence and security assessment reports for contracted custodians
- Performance evaluations and compliance reviews of custody providers

b) **Technical Services:**
- Contracts with blockchain analytics firms, including scope of services
- Technical consulting engagements related to cryptocurrency management
- Software licensing agreements for blockchain monitoring or wallet management tools
- Service agreements with security audit providers

c) **Legal and Financial Advisors:**
- Engagement agreements with external legal counsel specializing in digital asset matters
- Contracts with financial advisors providing cryptocurrency valuation services
- Consulting agreements related to regulatory compliance for digital assets

6. ACCOUNTING AND AUDIT RECORDS:

a) **Financial Reporting:**
- Balance sheet entries and supporting documentation relating to cryptocurrency holdings
- Methodology documents for financial statement recognition of digital assets
- Notes to financial statements addressing cryptocurrency holdings
- Disclosures provided to Government Accountability Office regarding digital assets

b) **Audit Documentation:**
- Internal audit reports concerning cryptocurrency holdings and operations
- External audit findings related to digital assets
- Management responses to audit findings
- Remediation plans for identified control weaknesses
- Proof-of-reserve verification protocols and results

TIME FRAME CONFIRMATION:

To eliminate any ambiguity, the timeframe for all requested records is:
January 1, 2022 – March 12, 2025 (Present)

LEGAL BASIS FOR DISCLOSURE:

The requested records are subject to disclosure under 5 U.S.C. § 552. The FOIA establishes a strong statutory presumption in favor of disclosure, placing the burden on the agency to justify withholding requested information. This presumption has been consistently recognized and enforced by federal courts. In support of this request, I reference the following authoritative case law and statutory provisions:

1. **Department of the Air Force v. Rose**, 425 U.S. 352, 361 (1976): Establishing that FOIA mandates a "general philosophy of full agency disclosure" and that exemptions must be "narrowly construed."

2. **NLRB v. Robbins Tire & Rubber Co.**, 437 U.S. 214, 242 (1978): Reinforcing that FOIA's "basic purpose reflected 'a general philosophy of full agency disclosure unless information is exempted under clearly delineated statutory language.'"

3. **FBI v. Abramson**, 456 U.S. 615, 630 (1982): Affirming that "FOIA exceptions are to be narrowly construed."

4. **United States Department of Justice v. Julian**, 486 U.S. 1, 8 (1988): Holding that the FOIA's "mandate of disclosure" requires federal agencies to disclose records unless they are specifically exempted.

5. **Public Citizen v. U.S. Dept. of Justice**, 491 U.S. 440, 449 (1989): Emphasizing the public's right to access government records to ensure governmental accountability.

6. **U.S. Department of Justice v. Tax Analysts**, 492 U.S. 136, 151 (1989): Confirming that agency financial records fall within FOIA's disclosure mandate and supporting the principle that FOIA requests need not demonstrate a "need to know."

7. **Milner v. Department of the Navy**, 562 U.S. 562, 565 (2011): Reiterating that FOIA "requires federal agencies to make Government records available to the public, subject to nine exemptions for specific categories of material."

8. **ACLU v. Department of Defense**, 543 F.3d 59, 66 (2d Cir. 2008): Holding that "FOIA was enacted to promote honest and open government and to assure the existence of an informed citizenry in order to hold the governors accountable to the governed."

9. **Multi Ag Media LLC v. Department of Agriculture**, 515 F.3d 1224, 1232 (D.C. Cir. 2008): Finding that disclosure of financial information in government possession serves FOIA's purpose of permitting public scrutiny of agency action.

10. **Bloomberg L.P. v. Board of Governors of the Federal Reserve System**, 601 F.3d 143 (2d Cir. 2010): Compelling disclosure of central bank financial records, establishing precedent for disclosure of government financial holdings.

11. **American Civil Liberties Union v. Department of Homeland Security**, 627 F.3d 227, 243 (D.C. Cir. 2010): Reiterating that the presumption of openness applies even when the records relate to government operations affecting public accountability.

12. **Electronic Privacy Information Center v. Department of Justice**, 416 F. Supp. 2d 30, 37 (D.D.C. 2006): Holding that "FOIA's purpose is to ensure an informed citizenry, vital to the functioning of a democratic society."

13. **National Archives and Records Admin. v. Favish**, 541 U.S. 157, 171-172 (2004): Reaffirming that FOIA's central purpose is to ensure that government activities are "opened to the sharp eye of public scrutiny."

14. **Cause of Action v. Federal Trade Commission**, 799 F.3d 1108, 1115 (D.C. Cir. 2015): Emphasizing that FOIA's goal is "to pierce the veil of administrative secrecy and to open agency action to the light of public scrutiny."

15. **Competitive Enterprise Institute v. Office of Science & Technology Policy**, 827 F.3d 145, 150 (D.C. Cir. 2016): Holding that records relating to government business are subject to FOIA regardless of where they are stored.

16. **Judicial Watch, Inc. v. U.S. Secret Service**, 726 F.3d 208, 216 (D.C. Cir. 2013): Defining agency records broadly to include materials that an agency has created, obtained, or controlled.

17. **EPIC v. DHS**, 999 F.3d 669, 675 (D.C. Cir. 2021): Reinforcing that the burden is on the agency to prove that requested documents fall within a FOIA exemption, not on the requester to prove they do not.

18. **Center for Investigative Reporting v. U.S. Department of Justice**, 982 F.3d 668 (9th Cir. 2020): Limiting the application of Exemption 7(A) for law enforcement records, particularly when related to completed enforcement actions.

In addition to this extensive case law, I note that the FOIA Improvement Act of 2016 (Public Law No. 114-185) further strengthens the presumption of openness by codifying the "foreseeable harm" standard, requiring agencies to withhold information only if "the agency reasonably foresees that disclosure would harm an interest protected by an exemption" or "disclosure is prohibited by law." This statutory requirement places an additional burden on the agency to justify any withholding of the requested records.

Furthermore, the OPEN Government Act of 2007 (Public Law No. 110-175) emphasizes timely responses to FOIA requests and mandates greater agency accountability in FOIA processing.

REQUEST FOR FEE WAIVER:

Pursuant to 5 U.S.C. § 552(a)(4)(A)(iii) and Treasury FOIA regulations at 31 C.F.R. § 1.7(k), I request a waiver of all search, review, and duplication fees associated with this request based on the following grounds:

1. **Public Interest Criterion:** Disclosure of the requested information is in the public interest because it will significantly contribute to public understanding of government operations and activities, specifically:

a) The requested records concern the operations and activities of the federal government in managing significant financial assets in the form of cryptocurrencies;

b) Disclosure will significantly enhance the public's understanding of how the Treasury Department manages digital assets, particularly in light of Executive Order 14178 establishing the Strategic Bitcoin Reserve;

c) The records will reveal how public funds and seized assets are being handled, providing transparency into an area of government activity that has received minimal public disclosure to date;

d) These records will contribute to the public's understanding of the implementation of a significant new government initiative that potentially impacts U.S. financial and monetary policy.

2. **News Media Dissemination:** As an investigative journalist, I will use these records to analyze and report on the Treasury Department's cryptocurrency activities through established news media channels, reaching a broad audience and enhancing public understanding of this government function.

3. **Not Primarily Commercial Interest:** The primary purpose of this request is journalistic and in the public interest, not for commercial benefit. Any commercial benefit that might accrue is incidental to the public purpose of informing citizens about government activities.

Should you deny this fee waiver request, please notify me before incurring any costs exceeding $100. In such case, I reserve the right to appeal the denial of the fee waiver and/or modify the scope of the request to reduce applicable fees.

EXPEDITED PROCESSING REQUEST:

Pursuant to 5 U.S.C. § 552(a)(6)(E) and 31 C.F.R. § 1.5(e), I request expedited processing of this FOIA request due to:

1. An urgency to inform the public about federal government activity that involves questions about the government's integrity, particularly regarding the implementation of Executive Order 14178 and the establishment of cryptocurrency reserves using public funds;

2. The matter is of widespread and exceptional media interest, with significant questions about the government's financial management practices that affect public confidence.

FORMAT OF PRODUCTION:

Please provide all responsive records in their native electronic format with all metadata intact. Specifically:

1. **Emails and Electronic Communications:**
- Provide in .MSG, .EML, or similar format that preserves all header information
- Include all attachments as separate files in their native formats
- Preserve complete metadata including routing information, timestamps, and delivery information
- Maintain threading and conversation indices
- Include server logs associated with transmission and receipt where available

2. **Structured Data:**
- Provide databases in their native format or as complete exports (SQL dumps, CSV, JSON, or XML)
- Include data dictionaries, schema documentation, and relationship diagrams
- Preserve all field names, table structures, and relationship information

3. **Documents and Reports:**
- Provide in native format (e.g., .DOCX, .XLSX, .PPTX) rather than as images
- If converted to PDF, ensure they are text-searchable and maintain metadata
- Preserve version history information where available

4. **Blockchain Data:**
- Provide wallet addresses and transaction hashes in machine-readable format
- Include blockchain explorer exports where available
- Maintain cryptographic integrity of any provided signatures or keys

5. **Calendar Items and Meeting Records:**
- Provide in .ICS or similar format that preserves attendee information and recurrence data
- Include meeting minutes as separate attachments in native format

This comprehensive preservation of metadata is essential to understanding the context, authenticity, and complete nature of the records being sought.

PRESERVATION OF RECORDS AND RIGHT TO APPEAL:

I request that all responsive records be preserved intact and without redaction pending the processing of this request. If you determine that any portion of the requested records is exempt from disclosure, I request that:

1. You provide a detailed Vaughn index specifically identifying each document withheld, the statutory exemption claimed, and a particularized explanation of how disclosure would damage the interests protected by the claimed exemption;

2. You release all reasonably segregable non-exempt portions of documents containing redacted material, pursuant to 5 U.S.C. § 552(b);

3. For each withholding decision, you articulate in writing the specific "foreseeable harm" that would result from disclosure, as required by the FOIA Improvement Act of 2016.

I expressly reserve the right to appeal any full or partial denial of this request, including any determinations regarding the applicability of exemptions, fee waiver denials, expedited processing denials, or regarding the adequacy of the search conducted. Further, I reserve the right to seek judicial review in federal court pursuant to 5 U.S.C. § 552(a)(4)(B) if the Department fails to comply with FOIA's requirements.

CONCLUSION:

Thank you for your prompt attention to this request. As provided by statute, I anticipate a determination on this request within 20 working days, unless expedited processing is granted, in which case a response is expected within 10 calendar days. Please provide a tracking number for this request

Sincerely,

Jordan Lassiter
Investigative Journalist