The IMF's terms govern "who spends money", but they cannot control "who receives Bitcoin".

Written by: Conflux

On September 17, according to on-chain data compiled by crypto KOL Yujin, the amount of Bitcoin in El Salvador's treasury account has risen to 7,777, with an unrealized gain of $162 million, a 37% increase.

If you remember the news from a year ago, it feels strange: Didn’t El Salvador already sign an agreement with the International Monetary Fund (IMF), promising not to use fiscal funds to buy Bitcoin anymore? How is this account's Bitcoin still increasing?

Appearing to Halt

Going back to December 2024, the IMF reached an agreement with El Salvador’s President Nayib Bukele’s government for a $1.4 billion, 40-month loan (Extended Fund Facility). The conditions were clear: Bitcoin would no longer be a mandatory legal tender; the private sector could voluntarily choose whether to accept it; on the public sector side, "Bitcoin-related transactions and purchases will be restricted."

In January 2025, El Salvador's parliament quickly amended the Bitcoin Law, which made it the world’s first country to adopt Bitcoin as legal tender in 2021. In February, the IMF’s executive board formally approved the disbursement. The IMF's country report in March provided more specifics: the new limit for Bitcoin purchases in the public sector is zero, the Fidebitcoin trust fund must liquidate by July 2025, and the government must withdraw from operating the national e-wallet Chivo.

According to this agreement, El Salvador's treasury should ideally stop accumulating Bitcoin starting in 2025.

Money Changes Identity

In reality, the rhythm of "buying one every day" has not stopped. This rhythm actually started in November 2022, earlier than what the outside world expected—Bukele announced this plan during the darkest moment of the FTX collapse when Bitcoin dropped below $16,000, on the grounds of "buying the dip". Three years later, it survived a bear market, a re-election, and a direct confrontation with the IMF; the only change is the narrative around the money.

In November 2025, El Salvador's "Bitcoin Office" announced a single-day increase of 1,090 Bitcoins, worth nearly $100 million, which conflicted with the IMF's supervision metrics, leading to external doubts that the agreement had broken down.

By September 2026, the IMF released the results of the second and third reviews, providing an explanation: all newly added Bitcoins after June 2025 came from "private donations" and the integration of internal treasury wallets, not from fiscal allocations. The majority of ownership and operational rights of the national e-wallet Chivo have also been transferred to a private operator, with the government retaining only a minority stake and custodial responsibility for user assets. The red line of "zero purchases with public funds" was literally upheld.

A Loophole in the Rules

The IMF's terms govern "who spends money", but they cannot control "who receives Bitcoin". As long as the buying is moved from the fiscal account to private donations, trust integrations, or the privatized Chivo, the Bitcoin in the treasury can still rise, and the narrative of "buying one every day" can continue to be told externally.

For Bukele, this arrangement is beneficial: it maintains the political banner of "Bitcoin Nation" and a national reserve with an unrealized gain of over 37%, while obtaining an additional $140 million in loans approved by the IMF, with over $3.5 billion in supportive funding from institutions like the World Bank and the Inter-American Development Bank lined up.

For the IMF, on the surface, it also wins—audit confirms that no new public funds were used to purchase Bitcoins, procedures are compliant, conditions met, and they can continue to disburse loans. As for whether the total amount of Bitcoin in the treasury has truly stopped growing because of this agreement, it is outside their verification scope.

What is truly diluted is the weight of the restriction of "zero purchases with public funds." It can constrain only the direct purchasing path taken by the treasury, but it cannot prevent buying behavior from continuing under a different accounting entity.

This outcome leaves an unresolved question: if the scale of "private donations" and wallet integrations continues to expand, even exceeding the quantity that the original "zero purchases" red line intended to constrain, will the IMF redefine what counts as "public funds" in its next review?

This 37% unrealized gain, so far, appears reasonable on paper. Whether it can remain reasonable depends on the IMF's willingness, and its ability, to push the boundaries of its reviews forward.