I asked about this to the IMF’s communications department and their response suggests a more flexible interpretation.

“The government under the program has committed not to accumulate further Bitcoins at the level of the overall public sector. We consulted with the authorities, and they have assured us that the recent increase in Bitcoin holdings in the Strategic Bitcoin Reserve Fund is consistent with agreed program conditionality,” they replied.

So, if bitcoin reserves have increased as the Bitcoin Office reported through X, how does that align with the commitment not to accumulate more?

Loopholes Of The IMF Restrictions On Bitcoin Purchases

Taking the agreement, this new clarification and Bukele’s post there some room to explain this apparent contradiction.

The strategic bitcoin reserve may be structured to keep it outside the official public sector, allowing it to increase its holdings without violating the agreement.

Another option is that not all accumulation is a purchase nor mining. If bitcoin reserves are growing through other financial operations instead of direct public sector involvement it’s not technically “accumulation” in the sense of the agreement.

El Salvador could also be reclassifying assets. Bitcoin could be moving between government-controlled entities without being considered a new acquisition. This might be problematic, as the staff report also explicitly states that all the wallets –hot or cold– must be identified.

The friendly answer from the IMF also suggests good terms between the Fund and El Salvador’s administration. If reserves are increasing under a policy that supposedly prohibits accumulation, the fact that the Fund clarified shows that there’s a standard criterion that is more flexible than what the documents explain.

The IMF Restrictions On Bitcoin Purchases Beyond The Headlines

On paper, El Salvador’s government is not breaking the agreement. However, the recent clarification from the IMF suggests there’s room for interpretation.

As long as Bitcoin holdings increase in a way that fits within the program’s framework, there’s no violation—at least for now.

El Salvador’s bitcoin strategy continues to challenge conventional financial norms, and its relationship with the IMF and other multilateral organizations remains critical to continue its development. The key question moving forward is whether these different interpretations of the scoop of the IMF restrictions on Bitcoin purchases will lead to conflict or simply become part of an evolving financial playbook.