In recent years, Bitcoin has moved beyond the status of a speculative asset. It is increasingly being adopted by governments, financial institutions, and pension funds worldwide. This growing institutional interest highlights Bitcoin's potential as a legitimate asset class and financial tool, suggesting that it is not merely a speculative "mania" but rather a groundbreaking asset with a role in modern financial transactions.
However, despite its rising acceptance, taking security over Bitcoin presents unique challenges for holders and lenders. In this first article in our series, "Securing Non-Traditional Assets," we delve into these challenges, exploring the issues that both parties face when using Bitcoin as security to acquire other assets or secure loans.
Challenges for Bitcoin holders
The primary challenge lies in the recognition and acceptance of Bitcoin as a form of security. Traditional financial systems and institutions are still grappling with the concept of digital assets, making it difficult for holders to leverage their Bitcoin effectively.
In addition, the volatile nature of Bitcoin's value adds another layer of complexity. Lenders may be hesitant to accept Bitcoin as collateral due to the potential for significant fluctuations in its value. This volatility can lead to concerns about the stability and reliability of using Bitcoin as security, thereby limiting its use in financial transactions
Challenges for Bitcoin lenders
From the lender's perspective, accepting Bitcoin as security presents its own set of challenges. One of the primary concerns is the digital nature of Bitcoin, which raises questions about the security and enforceability of the collateral. Unlike traditional assets such as real estate or physical commodities, Bitcoin exists entirely in the digital realm, making it more difficult to verify and secure.
Lenders must also contend with the issue of legal recognition and regulatory frameworks. As the legal landscape for Bitcoin continues to evolve, lenders are often unsure about the enforceability of their security interests in Bitcoin. This uncertainty can make lenders hesitant to accept Bitcoin as collateral, fearing that they may not have adequate protection or recourse in the event of default[1].
Additionally, the technical complexities associated with securing and managing Bitcoin add another layer of difficulty. Lenders need to have a deep understanding of digital wallets, private keys, and blockchain technology to ensure that the Bitcoin collateral is properly secured and accessible. This technical expertise is not always readily available, further complicating the process for lenders.
Furthermore, for those lenders regulated by the Australian Prudential Regulatory Authority, Bitcoin is not recognised as part of their Tier capital. This regulatory limitation hampers the ability of lenders to include Bitcoin in their capital adequacy assessments, with the consequence of restricting their capacity to accept it as collateral.
It is noteworthy that with the election of Donald Trump as President-Elect of the United States of America, Bitcoin is ‘planned’ to be treated as a reserve asset[2]. This potential policy shift could significantly impact the landscape of digital currency regulation and its acceptance in the financial sector. In addition, support in stabilising the volatility of Bitcoin is proposed to come in the form of a bill[3] entitled the Financial Innovation and Technology for the 21st Century Act which was passed by the House of Representatives (USA) on 22 May 2024 to establish a regulatory framework for digital assets and currently sits before the Senate.
Facing the challenges
How is Bitcoin treated?
Bitcoin is not defined under Australian property law. It has been described as an intangible asset[4] and therefore personal property and at other times it is attributed with currency qualities and therefore currency.
However, any perceived definition of Bitcoin is incongruent with both the common law and legislation dealing with personal property. It does not fit within current accepted principles under common law[5] which categorises personal property into two classes: choses in possession (tangible assets such as chattels or goods) or choses in action (intangible assets such as intellectual property rights or contractual rights)[6]. Notably though, tangible assets are created independently of the law while intangible assets are statutory creations[7] which lends itself to the creation or identification of new forms of personal property.
It does not fit within the legal definition of ‘currency’ under the Reserve Bank Act 1959 (Cth) and the Currency Act 1965 (Cth). These acts designate the Australian dollar as its official currency. According to these statutes, 'currency' refers to coins and banknotes that are legally recognised as a medium of exchange within the national economy.
It does not fit within any of the classifications of personal property under the Personal Property Securities Act 2009 (Cth) (PPSA) which establishes a legal framework for taking security over personal property.[8]
Differing views have also been proffered by regulatory and other professional bodies as to Bitcoin’s characterisation. For example, the Australian Tax Office (ATO)[9] treats Bitcoin as a form of property and categorises it as an asset for capital gains tax purposes. This classification means that buying, selling, or trading Bitcoin may result in a taxable event. The ATO does not consider Bitcoin as currency but as an asset subject to tax obligations similar to other investments.
Under the Australian Accounting Standards,[10] Bitcoin is generally treated as an intangible asset or financial instrument, depending on its use and context within a business. For instance, if held for trading, Bitcoin could be classified as inventory; however, in most cases, it is recognised as an intangible asset, reflecting its volatility and uncertain valuation over time.
The Reserve Bank of Australia (RBA) takes a more cautious approach to Bitcoin and does not recognise it as a reliable form of money or a significant component of the financial system. It sees Bitcoin more as a speculative asset which limits its acceptance in the financial system.
The RBA has indicated that Bitcoin does not meet the standards necessary to function as a stable form of money within Australia’s economy. It points to its volatility and the risks associated with Bitcoin, noting that this asset has characteristics more akin to commodities rather than currencies. Because the RBA considers Bitcoin as a speculative investment it has warned the public about potential financial loss due to extreme price fluctuations and regulatory uncertainties.[11]
Taking security by control
Because the existing legal framework does not adequately address the specific challenges posed by Bitcoin, the documentation used in these transactions must reflect its unique characteristics. For example, security agreements must incorporate provisions for the proper handling and safeguarding of digital collateral, including the management of private keys and digital wallets.
Another important aspect of the security arrangement includes the ability of the lender to adequately enforce their security interest. However, as explained above, under both the PPSA and the common law[12] Bitcoin is not recognised as personal property. Under the PPSA control refers to the lender's ability to manage and dispose of the collateral independently of the debtor. This means that should Bitcoin be regulated by the PPSA, and effectively utilised as collateral, lenders can ensure they have unequivocal control over the Bitcoin.
Left to the common law, without amendment to the PPSA and other relevant legislation, control over Bitcoin is more problematic. For tangible assets the lender has in the past included a right of entry to allow for repossession on default without recourse to the borrower. For intangible assets there were, prior to the passage of the PPSA, a myriad of laws regulating enforcement of a security interest. However, some if not all of these laws may now be repealed or inapplicable. This means for contractual rights, which a lender must now rely on, the enforcement rights and obligations are contained solely within the agreement between the lender and the borrower. This is further complicated by the nature of the debtor, whether they are a company or an individual. The Corporations Act 2001 (Cth) which regulates corporate structures including insolvency provisions, does not recognise assets such as Bitcoin. Even if this were the case, there are additional rules for enforcement depending on how Bitcoin is used, for example is it inventory, a trading item or a company asset for investment purposes? The old rules regarding taking a company charge have been deleted as they longer apply under the current regime.
Furthermore, depending on the terms of the loan agreement, the entry into the lending transaction may mean that it is a disposal of Bitcoin to the lender with a right to transfer it back to the borrower on repayment of the loan. Is there a legal or equitable assignment [transfer] of the Bitcoin? What is the borrower’s understanding of the loan agreement as to whether it is transferring its legal or beneficial interest in the Bitcoin?[13] More importantly, does the borrower or the lender have a legal and/or beneficial interest in the Bitcoin if it is not recognised as property for these types of transactions?
Assuming the lender has canvassed these deficiencies and determined its risk appetite (usually reflected in a substantially higher interest rate over traditional loans), the agreement can be drafted to allow the lender to manage and dispose of the Bitcoin without the consent of debtor through one or more of the control mechanisms described in detail below.
Taking control over Bitcoin is the only guarantee that the lender has to potentially enforce its loan in the event of default. This primarily involves securing the private keys associated with the Bitcoin. Private keys are cryptographic keys that grant access to the Bitcoin held in a digital wallet. The lender must ensure that these private keys are stored securely and are not accessible to unauthorised parties. There are several ways to achieve this:
· Custodial Services: Lenders can use third-party custodial services that specialise in safeguarding digital assets. These services provide secure storage solutions for private keys through the use of advanced security protocols, including encryption, multifactor authentication and often have insurance policies to protect against loss or theft, particularly comforting for lenders unfamiliar with digital asset handling.
A well-known custody service provider available in Australia is Coinbase Custody which provides custody solutions such as insurance coverage and regulatory compliance to institutions.
These custody services manage digital assets on behalf of their owners and usually store the private keys in cold storage (see below) to minimise the risk of hacking. Additionally, custodial services typically implement comprehensive compliance frameworks to meet the regulatory framework. Whilst not yet subject to anti money laundering legislation, Treasury[14] is pursuing the registration and reporting requirements of custody service providers for digital assets including Bitcoin. Registration and adherence to anti-money laundering and counter-terrorism protocols will add an extra layer of protection and act as countermeasure to fraud.
· Multi-Signature Wallets: Multi-signature (multi-sig) wallets require multiple private keys to authorise a transaction. This means that control is shared between the lender and the borrower, or potentially other parties, which adds a layer of security and flexibility in the number of signatories (e.g 2 out of 3 or 3 out of 5 signatories). The lender is assured that no transactions can occur without their approval.
A multi-signature wallet provider is BitGo, which is popular and widely used in Australia among businesses and institutional investors for securing their Bitcoin. BitGo uses multi-signature technology to require multiple keys (from different parties) to authorise a transaction.
· Cold Storage: Cold storage refers to storing private keys offline, away from any internet connection, significantly reducing the risk of hacking. Lenders can use hardware wallets or paper wallets stored in secure physical locations to achieve cold storage. By using offline wallets, the offline keys are not exposed to online vulnerabilities such as phishing or malware attacks. Cold storage is widely regarded as the most secure form of storing Bitcoin.
The two most widely recognised hardware wallet providers, both of which are available in Australia, are Ledger and Trezor. Their wallets store private keys offline and require physical access to authorise transactions making them very secure against online threats.
The wallets can be purchased through various online retailers and digital currency exchanges that operate within Australia.
· Smart Contracts: Smart contracts are self-executing contracts with the terms of the agreement directly written into code. They can be programmed to automatically release Bitcoin to the lender once certain conditions have been met, ensuring control and enforceability. Human intervention and fraud are minimised and enforcement on specific conditions underscores their unique benefits.
The benefits of using smart contracts are undeniable. As the contract operates on the blockchain it is immutable and transparent providing an auditable record of all actions and conditions.
Compound is a global decentralised finance (DeFi) platform that uses smart contracts to facilitate lending and borrowing of digital assets. Lenders can provide Bitcoin as collateral and the smart contract automatically enforces the terms of the loan including disbursement of funds and the liquidation of collateral if required.
Additional methods for taking control
· Escrow arrangements: Some lenders use third-party escrow services where Bitcoin is held in trust until loan conditions are met. These third-party arrangements can provide an additional layer of security, especially if the lender lacks digital asset expertise. Escrow is particularly useful for larger transactions, as it minimises risk for both parties.
· Blockchain-Based Collateral Management Platforms: New blockchain platforms provide infrastructure specifically for lending against digital assets. They offer features such as real-time collateral monitoring and automated liquidation if the asset’s value drops below a specified threshold.
· Direct Control Agreements with the Borrower: For some lenders, establishing a direct agreement where the borrower maintains Bitcoin in a designated wallet with regular audits or “view-only” access is an option. This method is less robust but can be practical for smaller loans or when both parties have a high level of trust.
It is clear that each of these control methods do offer significant security in the form of control which in turn reduces the risk of unauthorised access, loss or fraud. Smart contracts in particular represent a transformative tool in the lending industry, automating the execution of loan agreements and providing a decentralised, secure and transparent environment for both the lender and the borrower.
Ensuring clarity of both the control aspect and enforcement action in the loan documentation is critical in fostering confidence among lenders and facilitating the broader acceptance of Bitcoin as a viable form of security.
Including Bitcoin in the PPSA framework
For Bitcoin to be fully incorporated into the PPSA, certain aspects of the legislation need to be adapted to account for its unique nature. Bitcoin could fit into the PPSA framework by making a few minor changes discussed further below. Whilst there are recommendations to include Bitcoin as an intangible asset, it may be more appropriate to characterise Bitcoin as a currency.
Possible changes to include Bitcoin as an intangible asset
This could involve:
· clarification on Control: Adjustments to define what is “control” over Bitcoin. As mentioned above, control under the PPSA generally involves the ability to access and dispose of the asset, which in the case of Bitcoin means controlling the private keys.
· amendments to the definition of Intangible Assets: Explicitly recognising Bitcoin as an intangible asset within the PPSA to prevent confusion over its classification and treatment under the Act.
With these minor changes, Bitcoin would be considered an intangible asset, and security interests over it would be perfected through control of the private keys associated with the Bitcoin. This would mirror how other forms of intangible property are treated under the Act[15].
Possible changes to include Bitcoin as currency
If the Australian government were to officially recognise Bitcoin as a form of "currency," it could be classified as "currency" rather than an "intangible asset."
This could involve:
· currency classification: Under the PPSA, currency is generally treated as a medium of exchange authorised by the Australian government. This would allow it to be more easily used as collateral with well-defined security interest processes.
· impact on Security Interests: Recognising Bitcoin as currency would mean security interests over it would be managed in the same way as traditional currency. Security over currency often involves physical possession or control, but the PPSA could be amended to include digital control measures, such as holding private keys or using custodial services.
· shift from Intangible Asset to Currency: Treating Bitcoin as an intangible asset under the PPSA appears to be based on the fact that it is not backed by the government and lacks physical form. This classification impacts on how security interests are registered and perfected, as intangibles are managed differently, usually requiring registration on the Personal Property Securities Register. Recognition as currency would allow Bitcoin to be secured more easily in line with other forms of recognised currency[16].
In summary, reclassification of Bitcoin as currency would simplify the management and perfection of security interests over Bitcoin, aligning it more closely with traditional financial systems. It makes sense to characterise Bitcoin as currency, despite the RBA’s reservations, particularly with the forthcoming regulation of digital currency exchanges which should alleviate its concerns about money laundering. Of particular note is the definition of ‘digital currency’ in the anti-money laundering legislation which aligns with the Currency Act’s definition but is more extensive to include digital mediums of exchange.[17]
There are several other factors that support Bitcoin’s classification as currency:
· adopted as currency: It has already been unofficially adopted as currency. Australia has seen a marked increase in the number of Bitcoin ATMs[18], which bridge the gap between traditional financial systems and the burgeoning world of digital currencies.[19]
· used in the purchase of goods and services: While originally envisioned as a decentralised alternative to traditional currencies, Bitcoin has evolved beyond just being a medium of exchange. Bitcoin can be used to purchase a wide range of goods and services, both online and offline. Many businesses, ranging from small enterprises to large corporations, have begun accepting Bitcoin as a form of payment.
· used as savings earning interest: Platforms such as BlockFi and Celsius Network[20] offer interest-bearing accounts for Bitcoin, allowing users to earn interest on their holdings.
· ideal for remittances and cross border transactions: Bitcoin's decentralised nature makes it an ideal medium for remittances and cross-border transactions, enabling near-instantaneous transactions with relatively low fees.
· philanthropic use: Several non-profit organisations and charities accept Bitcoin donations, leveraging the transparency and security of blockchain technology.[21]
· a replacement for CBDCs: Bitcoin maintains certain privacy advantages over CBDCs because of its decentralised design and pseudonymity. The government should be comforted by the fact that its public ledger still allows for some tracking.
· global recognition as currency: several countries have taken steps to officially recognise Bitcoin as a form of currency, for example: El Salvador,[22] Ukraine, the Central African Republic and Paraguay. Several other countries have taken steps to regulate and recognise Bitcoin within their financial systems, albeit not as legal tender. These countries include Japan, Germany, Malta and Switzerland.
By including Bitcoin in the PPSA as personal property it will overcome some of the legal uncertainty surrounding its usage and adoption.
Conclusion
Bitcoin's status as a non-traditional asset highlights the need for a more robust and comprehensive legal framework to address the complexities of taking security over digital assets. First, Bitcoin should be acknowledged as personal property, and ideally, it should be classified as currency. This classification would reflect its dual role beyond just a medium of exchange, as it now holds utility in a range of financial applications and as a form of investment. Other jurisdictions, such as China, have begun to recognise this utility value, acknowledging Bitcoin’s role as a medium of settlement within blockchain systems and securities transactions.
Currently, both Bitcoin holders and lenders face challenges due to regulatory ambiguity and technical barriers, underscoring the need for policy makers to formalise Bitcoin’s place within financial systems. While the existing PPSA framework remains inadequate, there is a pressing need for legislative reform to classify Bitcoin as personal property and to support its use in secure lending practices. The Personal Property Securities Amendment (Framework Reform) Bill, recently under review, presents an opportune moment to engage with policymakers and address these gaps. As part of this evolving landscape, practitioners are encouraged to employ well-drafted agreements, including those facilitated by smart contracts and DeFi lending platforms, to safeguard their interests.
As the financial world continues to adapt to digital assets, establishing clarity and legal protections will be critical in unlocking Bitcoin's full potential as a form of security. In our next article, we will focus on securing gold as a non-traditional asset.
Readers should note the importance of professional legal and financial advice when engaging in Bitcoin-backed loans to ensure that that they take a cautious and informed approach.
Stay tuned for our next article where we will consider securing another non-traditional asset: a focus on gold.
[1] See the High Court (UK) case of Southgate v Graham [2024] EWHC 1692 (Ch) found at https://assets.caselaw.nationalarchives.gov.uk/ewhc/ch/2024/1692/ewhc_ch_2024_1692.pdf where the claimant sought specific performance of his Ethereum tokens given as security for an alleged loan which had a fourfold increase in value. The court upheld the lower court’s decision to award damages rather than specific performance.
[3] See https://www.congress.gov/bill/118th-congress/house-bill/4763. Whilst the bill passed the House on 22 May 2024 and was Received by the Senate on 9 September 2024, the Senate, following its Reading the bill a second time, referred it to the Committee on Banking, Housing, and Urban Affairs where it currently sits.
In the United Kingdom, the legal recognition of digital assets such as Bitcoin is being addressed through the introduction into Parliament on 11 September 2024 of the Property (Digital Assets etc) Bill which aims to classify digital assets, including cryptocurrencies and Non-Fungible Tokens, as personal property. The bill's purpose is to ensure that Bitcoin and similar assets are protected under English and Welsh law. See https://www.google.com/url?sa=t&source=web&rct=j&opi=89978449&url=https://www.gov.uk/government/news/new-bill-introduced-in-parliament-to-clarify-cryptos-legal-status%23:~:text%3DThe%2520Property%2520(Digital%2520Assets%2520etc,personal%2520property%2520under%2520the%2520law.&ved=2ahUKEwj4t9y17M6JAxV41jgGHfusKI8QFnoECBwQAw&usg=AOvVaw1m4M0zfVmtOPSGW5VXIW9U
As for the European Union (EU) regulations vary by country, but there is a clear trend toward treating cryptocurrencies as assets, albeit with different classifications depending on the jurisdiction. In relation to the EU itself, the Markets in Crypto-Assets Regulation came into force in June 2023 with implementation proposed for 30 December 2024. The Regulation aims to provide uniform rules across the EU for crypto assets, intending to boost market stability and protect investors. See https://www.esma.europa.eu/esmas-activities/digital-finance-and-innovation/markets-crypto-assets-regulation-mica.
In China, the Chinese People’s Court in its report entitled “Identification of the Property Nature of Virtual Currency and Issues Related to the Disposal of Assets Involved” released on 1 September 2023 recognises ‘virtual currency’ as property which is protected by law. See https://www.aicoin.com/en/article/363669
[4] Various published articles have characterised Bitcoin (or more generally digital assets under which Bitcoin would fall) as an intangible asset. See for example: https://kpmg.com/us/en/frv/reference-library/2024/accounting-and-reporting-for-crypto-intangible-assets.html
[5] Australia is a common law jurisdiction and these same principles apply, subject to case law and legislative amendment.
[6] See the Law Commission’s (UK) Report to the government dated 28 June 2023 which highlights the deficiencies in the common law concept of personal property, and can be found here: https://lawcom.gov.uk/project/digital-assets/. In contrast, the Hong Kong Court applied the common law definition of “property” established in National Provincial Bank v Ainsworth [1965] AC 1175 (the Ainsworth case) to determine whether “cryptocurrency” constitutes property. Applying a 4-pronged test and with reference to the unique characteristics of cryptocurrency, including the public key (equivalent to a bank account number) and the private key (equivalent to a PIN or password), the Hong Kong Court held that cryptocurrency had all the qualities of “property”. See also Gendall J’s comments in the High Court of New Zealand case of Ruscoe v Cryptopia Limited (in liq) [2020] 2 NZLR 809, where, after considering the Ainsworth case, he held that the cryptocurrencies in question were a species of intangible personal property. For a discussion on further cases that consider the characterisation of ‘cryptocurrencies’ see His Honour Justice Jackman’s speech entitled Is Cryptocurrency Property? found here: https://www.fedcourt.gov.au/digital-law-library/judges-speeches/justice-jackman/jackman-j-20240621
[7] For example, copyright and trademarks. [7] See the Australian Law Reform Commission’s Report 129 where in defining property it stated [at18.24] “Understandings about what amounts to property reveal a certain fluidity when viewed historically. As one stakeholder commented: “The rights that attach to different objects, be they land, personal or intellectual property are not frozen in time. Just as for all legal rights, the nature and content of property rights will evolve and potentially change quite significantly over time.”” Environmental Justice Australia, Submission 65. property (See further at https://www.alrc.gov.au/publication/traditional-rights-and-freedoms-encroachments-by-commonwealth-laws-alrc-report-129/18-property-rights/definitions-of-property-3/ )
See also the Law Commission’s (UK) attempt to change the common law accepted principles in the form of a bill. Ibid at 6.
[8] Interestingly the government has not recognised the fluidity of property as there appears to be no attempt to create a statutory common law property right in Bitcoin or an amendment to the PPSA to recognise Bitcoin as personal property. However, see https://treasury.gov.au/sites/default/files/2023-10/c2023-427004-fs.pdf where Treasury has recommended regulating “digital and crypto asset” platforms. See further discussion on the control mechanism by custody service providers in this article.
[9] Section 40-100(2) of the Income Tax Assessment Act 1997 (IATA) clarifies that Bitcoin is treated as property and falls under the same treatment as other types of intangible assets for capital gains tax purposes. The treatment of Bitcoin under the IATA is primarily found in the context of Capital Gains Tax (section 108-5) and personal use exemptions (section 118-20). See also section 15-15 which relates to GST and initially treated digital currencies, including Bitcoin, as taxable for GST purposes. However, this was amended by Schedule 1 Treasury Laws Amendment (2017) to exclude digital currencies from GST, so Bitcoin transactions are now GST-exempt.
[10] While there is no specific accounting standard that directly addresses Bitcoin, several standards and guidance can be applied depending on the context in which Bitcoin is held (e.g. as an investment, inventory, or for trading purposes). A relevant standard includes AASB 138 - Intangible Assets
which primarily governs the recognition and treatment of intangible assets. Bitcoin is generally treated as an intangible asset under this standard because it lacks physical substance and has no fixed maturity.
[12] However, see Ibid at 6.
[13] There may be taxation implications for a ‘disposal’ of Bitcoin depending on whether there is a capital gain or income received.
[14] See Treasury’s Report on Regulating Digital Exchange Platforms last updated on 16 October 2023 which can be found here: https://treasury.gov.au/sites/default/files/2023-10/c2023-427004-fs.pdf
[15] For example, intermediated securities are specifically catered for under an agreement between the holder and an intermediary (stockbroker) who manages them through the Clearing House Electronic Sub-register System (CHESS) under a CHESS sponsorship agreement which includes a ‘Holder Register Lock’ preventing unauthorised removal from the holdings.
[16] Ss 36(1) of the Reserve Bank Act and s. 16 of the Currency Act.
[17] S. 5 Anti‑Money Laundering and Counter‑Terrorism Financing Act 2006
[18] See chart on the exponential growth of Bitcoin ATMs in recent years at https://coinatmradar.com/charts/growth/australia/
[19] For a detailed explanation of Bitcoin ATMs growth and how they work see https://localcoinatm.com/en-au/blog/state-of-bitcoin-atms-in-australia/
[20] See https://coincodecap.com/blockfi-vs-celsius-vs-hodlnaut#h-blockfi-interest-rates for a full description of interest rates paid on Bitcoin and other digital assets.
[21] There is clear authority from both case law and governmental authorities that Bitcoin is property. See the Ainsworth case mentioned:Ibid at 8 and The People’s Court Report where it was stated that “[u]nless it is used for illegal activities by the holder or directly originates from the holder's illegal activities, the property rights and interests of virtual currency holders should be protected”.https://www.aicoin.com/en/article/363669
[22] In June 2021, El Salvador became the first country in the world to officially recognise Bitcoin as legal tender. The "Bitcoin Law" mandates that Bitcoin be accepted as a form of payment throughout the country, alongside the US Dollar, which has been the official currency since 2001. The government has also launched a national digital wallet called "Chivo " to facilitate Bitcoin transactions.
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