U.S. Bitcoin Treasury Strategy and Regulatory Silence: Insights from Jack Mallers' Accumulation and Advocacy

In Q2 2025, the intersection of Bitcoin accumulation, institutional adoption, and regulatory ambiguity has become a focal point for investors and policymakers alike. At the center of this dynamic is Jack Mallers, CEO of Strike and co-founder of Twenty One Capital (ticker: XXI), whose public advocacy and strategic Bitcoin accumulation reveal critical insights into the U.S. government's evolving stance on digital assets. This article examines how Mallers' actions and rhetoric illuminate broader trends in institutional adoption, market sentiment, and potential regulatory shifts.

Mallers' Bitcoin Accumulation: A Strategic Bet on Institutionalization

Twenty One Capital, formed via a SPAC merger with Cantor Equity Partners, has emerged as a trailblazer in institutional Bitcoin adoption. As of Q2 2025, the firm holds 37,230 BTC, acquired during periods of market consolidation below $90,000. Notably, XXI has not sold any of its holdings since April 2025, signaling a long-term commitment to Bitcoin as a strategic reserve asset. This approach mirrors the strategies of firms like MicroStrategy and Marathon Digital, which have positioned Bitcoin as a hedge against inflation and geopolitical uncertainty.

Mallers' emphasis on “Bitcoin Ownership Per Share” (BPS) as a key metric underscores a paradigm shift in corporate finance. By prioritizing Bitcoin accumulation over traditional earnings metrics, XXI challenges conventional valuation models and aligns with a growing cohort of companies treating Bitcoin as a non-sovereign store of value. This strategy is not without risk—Bitcoin's price volatility remains a concern—but the broader trend suggests that institutional players are increasingly prioritizing Bitcoin's scarcity and anti-fragile properties over short-term liquidity.

Public Advocacy and the Critique of U.S. Government Transparency

Mallers has been a vocal critic of the U.S. government's handling of its Bitcoin reserves. He argues that the delayed audit of the Strategic Bitcoin Reserve (SBR)—announced in March 2025—reflects a lack of transparency and undermines the U.S.'s credibility as a global crypto leader. The reported discrepancy between earlier estimates of 200,000 BTC and the U.S. Marshals Service's 28,988 BTC holdings raises questions about whether prior administrations liquidated significant portions of seized Bitcoin. Mallers' skepticism is further fueled by the transfer of 30,175 BTC to Coinbase Prime in April 2024, which he interprets as evidence of a fragmented and reactive government strategy.

This critique is not merely academic. Mallers frames government accumulation as a critical driver of Bitcoin's legitimacy and price. He argues that for the U.S. to assert itself as the “global crypto capital,” it must accumulate Bitcoin at scale—a move that would tighten supply and reinforce Bitcoin's role as a reserve asset. His advocacy aligns with broader market sentiment: Bitcoin surged to $114,000 in Q2 2025, with 92% of all coins mined and a significant portion held in long-term wallets.

Regulatory Developments: A Tipping Point for Institutional Adoption?

The regulatory landscape in Q2 2025 has been marked by both progress and ambiguity. The passage of the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act in June 2025 provided a bipartisan framework for stablecoin regulation, while the U.S. Department of Labor's rescission of 2022 retirement account guidance opened the $8.7 trillion 401(k) market to crypto investments. Additionally, the appointment of Paul Atkins as SEC Chairman—a pro-crypto advocate—signaled a potential shift in regulatory tone.

Mallers' public statements suggest he views these developments as a catalyst for institutional adoption. By advocating for government transparency and accumulation, he indirectly pressures regulators to create a more structured environment for Bitcoin. His criticism of the SBR audit delay, for instance, highlights the need for clear governance frameworks—a gap that the GENIUS Act and other legislative efforts aim to address.

Investment Implications: Navigating the New Normal

For investors, the convergence of Mallers' accumulation strategy, institutional adoption trends, and regulatory developments presents both opportunities and risks. Key considerations include:

1. Bitcoin Treasury Companies as a New Asset Class: Firms like XXI, Nakamoto, and Strive are redefining corporate treasuries by prioritizing Bitcoin. These companies offer exposure to Bitcoin's upside while leveraging capital markets to scale holdings. However, their success depends on regulatory clarity and sustained Bitcoin price action.

2. Regulatory Uncertainty as a Double-Edged Sword: While the GENIUS Act and pro-crypto leadership at the SEC are positive signals, the absence of a comprehensive framework for Bitcoin itself remains a risk. Investors should monitor the House's consideration of the STABLE Act and the broader CLARITY Act, which could shape the future of institutional adoption.

3. Geopolitical and Macroeconomic Tailwinds: Rising fiscal spending, geopolitical tensions, and the U.S. dollar's relative weakness continue to drive demand for Bitcoin as a hedge. Mallers' advocacy for government accumulation aligns with this narrative, suggesting that Bitcoin's role as a reserve asset is likely to expand.

Conclusion: A Call for Strategic Positioning

Jack Mallers' public accumulation and advocacy reveal a broader narrative: Bitcoin is transitioning from a speculative asset to a cornerstone of institutional portfolios. While regulatory silence and government opacity remain challenges, the actions of figures like Mallers—and the regulatory progress of Q2 2025—suggest that the U.S. is inching toward a more structured approach to digital assets.

For investors, the key takeaway is to position for a future where Bitcoin is not just a hedge but a strategic reserve asset. This means allocating to Bitcoin treasury companies, monitoring regulatory developments, and maintaining exposure to Bitcoin itself. As Mallers has argued, the U.S. has “no choice but to accumulate” if it wants to lead in the crypto era. The question is not whether Bitcoin will become mainstream, but how quickly institutions—and regulators—will adapt.