Could the U.S. Build a Bitcoin Fortress? Treasury to Study Strategic Holdings, Cyber Risks, and Accounting Gaps

A proposed U.S. House bill, introduced on September 9, 2025, could trigger a Treasury Department study into the feasibility of establishing a Strategic Bitcoin Reserve. The legislation mandates an investigation into federal custody mechanisms, cybersecurity protocols, and accounting standards necessary for such an initiative. While the bill is still in early stages, it reflects growing interest among policymakers in evaluating the role of Bitcoin as a strategic asset. The study is expected to assess the practical, economic, and security implications of holding Bitcoin reserves, potentially influencing future federal policy decisions.

The bill aligns with ongoing discussions on how to manage and account for digital assets, a topic that has drawn attention from major financial institutions and regulatory bodies. The American Institute of Certified Public Accountants (AICPA) has already developed nonauthoritative guidance on auditing and accounting for cryptocurrencies and other digital assets. This guidance, developed by the AICPA’s Digital Assets Working Group, includes insights on the challenges and risks associated with digital asset accounting under both IFRS and U.S. GAAP standards. The introduction of the bill adds a new dimension to these discussions by proposing federal-level oversight and control mechanisms.

Cybersecurity is a central concern in the bill, with legislators emphasizing the need for robust federal custody frameworks. The AICPA has previously highlighted the risks posed by blockchain technology, particularly in service organizations that rely on such systems for operations like supply chain efficiency. While blockchain offers benefits like reduced costs and increased transparency, it also introduces new vulnerabilities that require careful management. The proposed study would assess how current cybersecurity practices could be adapted to meet the unique challenges of securing large-scale Bitcoin holdings.

The role of custodians in digital asset management is another key focus area in the broader financial landscape. The AICPA has previously emphasized the importance of custodians in Bitcoin adoption, noting that Bitcoin’s decentralized properties necessitate reliable custodial solutions to ensure asset security and investor confidence. The proposed Treasury study is expected to explore whether federal agencies have the capacity and infrastructure to function as custodians, or whether partnerships with private sector entities would be more viable.

The bill also raises questions about how digital assets should be integrated into the broader financial ecosystem. The Federal Reserve has long been focused on maintaining public confidence in the U.S. dollar and payment systems. As digital currencies gain traction, there is an increasing need to evaluate how traditional financial frameworks can adapt to include these new forms of value. The bill's proposal could serve as a catalyst for broader discussions on the evolving role of the U.S. dollar and digital payment systems in the age of digital transformation.

The House bill underscores the growing recognition of digital assets as a serious financial category that warrants careful regulation and oversight. As the Treasury prepares to conduct its study, it will likely draw on existing guidance from bodies like the AICPA, as well as insights from blockchain technology experts and accounting professionals. The outcomes of the study may shape not only U.S. policy but also set a precedent for other nations considering similar approaches to digital asset management.