Cristosal presents its analysis of the accumulation of bitcoins in El Salvador through private donations, transactions carried out without meeting international fiscal transparency standards, with no evidence that authorities fulfilled their anti-money laundering obligations, and despite the commitment made to the IMF to “keep unchanged the total bitcoins held by the public sector.” The document examines how the Government, while meeting the macroeconomic targets of the Extended Fund Facility (EFF) agreed in 2025, repeatedly failed to comply with the structural conditions on bitcoin, governance, and transparency. Drawing on GAFILAT’s 2024 mutual evaluation report, FATF standards on virtual assets, and past fraud involving Chivo Wallet, it identifies four risks: money laundering, failure to implement the Travel Rule in practice, vulnerabilities in the real estate sector and the Freedom Passport program, and the possibility that donations function as upfront bribes, punishable under the United Nations Convention against Corruption and the FCPA. The analysis concludes that the State must disclose donors’ identities, amounts, and dates; carry out the due diligence required by the Law Against Money and Asset Laundering; audit the traceability of funds on the blockchain; and close regulatory gaps on cryptoasset donations and political financing. It also argues that the IMF has required only formal compliance with structural benchmarks, a leniency that has encouraged noncompliance.

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