Bitcoin Estate Planning for Government Employees: TSP, Security Clearances, and Federal Ethics Rules in 2026

You serve the public. You hold a clearance. You file disclosure forms that become part of your permanent record. And you own Bitcoin.

That combination creates estate planning constraints that no private-sector guide addresses. The Thrift Savings Plan — the best employer-matched retirement vehicle available to federal workers — offers zero Bitcoin exposure. Your financial disclosure obligations mean your Bitcoin position is not private. Your security clearance requires that every asset be explainable, documented, and consistent with your income. And conflict-of-interest rules may prevent you from participating in official actions that touch cryptocurrency policy.

None of this means you cannot hold Bitcoin. Federal employees absolutely can — and many do. But the estate plan that protects a Bitcoin-holding software engineer in Austin will not work for a GS-15 at Treasury, an O-5 with TS/SCI clearance, or a state employee with a pension that creditors cannot touch while Bitcoin sitting in a personal wallet has no such protection.

This guide covers every constraint unique to government employees building a Bitcoin estate plan in 2026 — from OGE forms to the Hatch Act, from TSP strategy to deployment planning, and from conflict-of-interest recusals to trust structures that satisfy ethics counsel.

For the foundational Bitcoin estate planning framework, see our complete Bitcoin estate planning guide. This article addresses the federal-specific layers that sit on top of that framework.

Financial Disclosure: Bitcoin on the Record

Federal financial disclosure is the first constraint most government Bitcoin holders encounter. Unlike private-sector employees, who have no obligation to report personal investments to their employer, covered federal employees must disclose assets — including cryptocurrency — on standardized forms reviewed by ethics officials.

OGE Form 278e: Public Financial Disclosure

Senior officials — including Senate-confirmed appointees, Senior Executive Service members, and certain Schedule C political appointees — file OGE Form 278e. This form is public. Anyone can request a copy under the Ethics in Government Act.

Bitcoin holdings must be reported as an asset on Schedule A. You report the asset description ("Bitcoin" or "BTC — cryptocurrency"), the value range (using OGE's brackets: $1,001–$15,000, $15,001–$50,000, $50,001–$100,000, $100,001–$250,000, and so on up to "over $50,000,000"), and any income or gain from the asset during the reporting period.

For a senior official holding 20 BTC — worth roughly $2 million at current prices — this means a public record discloses a seven-figure cryptocurrency position. The privacy implications are significant. Anyone with access to FOIA or the agency's ethics office can determine that a named official holds a substantial Bitcoin position, the approximate value range, and whether they sold, staked, or earned income from it during the year.

OGE Form 450: Confidential Financial Disclosure

Covered employees below the senior official threshold — typically GS-15 and above in certain positions, contracting officers, and employees in positions identified by their agency as having significant decision-making authority — file OGE Form 450. Unlike the 278e, this form is confidential. It is reviewed by ethics officials but not available to the public.

Bitcoin still must be disclosed. The 450 requires reporting assets held for investment that exceed $1,000 in value or that produced more than $200 in income during the reporting period. The confidentiality provides some privacy protection, but the information is still accessible to your agency's ethics office, the Office of Government Ethics, and investigators with appropriate authority.

Privacy Strategies Within Disclosure Rules

You cannot avoid disclosure. But you can structure your holdings to minimize unnecessary exposure:

• Trust reporting. Bitcoin held in a revocable living trust is still reportable (you are the beneficial owner). Bitcoin held in an irrevocable trust where you are not a beneficiary and have no control may fall outside your reporting obligation — consult your DAEO. This creates a legitimate reason to accelerate irrevocable trust planning. See our trust vs. will comparison for the structural differences.
• Gift and estate transfer. Bitcoin gifted to family members (within the $19,000 annual gift exclusion for 2026, or using lifetime exemption) is no longer your asset and no longer reportable on your disclosure form. The recipient has no federal disclosure obligation unless they are also a covered employee.
• Spousal holdings. Your spouse's assets are also reportable on both the 278e and 450. However, the reporting thresholds and review standards differ slightly. Transferring Bitcoin to a spouse does not eliminate your disclosure obligation.

The fundamental tension: financial disclosure exists to prevent conflicts of interest, and that goal is legitimate. But for high-net-worth government employees, it creates a privacy cost that private-sector holders do not bear. Your estate plan should acknowledge this reality and, where appropriate, use irrevocable structures that legitimately remove assets from your reportable portfolio while accomplishing genuine estate planning objectives.

Security Clearances and Bitcoin: What Investigators Actually Look For

Security clearance adjudication under Security Executive Agent Directive 4 (SEAD 4) evaluates 13 guidelines. Guideline F — Financial Considerations — is where Bitcoin intersects with clearance eligibility.

Holding Bitcoin does not disqualify you from a clearance. The concern is not the asset class. The concerns are:

• Unexplained wealth. A GS-13 earning $115,000 per year who holds $3 million in Bitcoin will be asked to explain the acquisition timeline. If you bought early, you need documentation — exchange records, blockchain transaction history, tax returns showing reported gains. If the wealth cannot be explained by your income, inheritance records, or documented appreciation, it becomes a Guideline F issue.
• Foreign transactions. Peer-to-peer Bitcoin purchases from foreign counterparties, use of foreign exchanges, or Bitcoin received from foreign sources can trigger Guideline B (Foreign Influence) concerns in addition to Guideline F. Investigators look at whether foreign actors could use your cryptocurrency activity as leverage.
• Unreported holdings. If your SF-86 (Questionnaire for National Security Positions) asks about financial accounts and you fail to disclose cryptocurrency holdings, that is a Guideline E (Personal Conduct) concern — dishonesty or lack of candor during the investigation process. This is often more damaging to clearance adjudication than the underlying financial issue.
• Excessive trading and financial instability. Day-trading cryptocurrency, margin trading, or frequent leveraged positions can suggest financial instability or gambling behavior — both Guideline F concerns. Long-term Bitcoin holding with a documented investment thesis is viewed very differently from speculative trading.

CI Polygraph and Cryptocurrency

Employees undergoing counterintelligence (CI) polygraph examinations — standard for TS/SCI access at intelligence community agencies — should be aware that financial questions may cover cryptocurrency. Polygraph examiners may ask about unreported income, undisclosed assets, or financial relationships with foreign nationals. If you hold Bitcoin and have not disclosed it on your financial forms, the polygraph becomes a trap of your own making.

The solution is straightforward: disclose everything, keep records of all acquisitions and dispositions, report all gains on your tax returns, and ensure your SF-86 and financial disclosure forms are consistent and complete. A clearance holder with 50 BTC, fully documented and reported, is in a stronger position than one with 0.5 BTC that was never mentioned.

The TSP Problem: No Bitcoin, But Still Your Best Retirement Tool

The Thrift Savings Plan is the federal employee's 401(k). It offers five core investment funds — the C Fund (S&P 500 index), S Fund (small/mid-cap index), I Fund (international index), F Fund (bond index), and G Fund (government securities) — plus Lifecycle (L) funds that blend these based on target retirement dates.

There is no Bitcoin fund. No cryptocurrency fund. No Bitcoin ETF option. Despite the approval of spot Bitcoin ETFs in January 2024 and their subsequent inclusion in many private-sector 401(k) plans, the Federal Retirement Thrift Investment Board (FRTIB) — which governs the TSP — has not added any cryptocurrency exposure as of 2026.

This creates a strategic question: how should a federal employee who wants Bitcoin exposure allocate across TSP and non-TSP accounts?

The Two-Bucket Strategy

The answer is simple in concept, nuanced in execution:

Bucket 1: TSP. Maximize your TSP contributions ($23,500 in 2026, plus $7,500 catch-up if over 50). Capture the full agency match under FERS (5% of basic pay). Allocate within TSP based on your overall portfolio strategy — but accept that this bucket will be traditional equities, bonds, and government securities. The TSP's rock-bottom expense ratios (roughly 0.05% across all funds) and tax-deferred growth make it the single best retirement accumulation vehicle available to you, even without Bitcoin.

Bucket 2: Bitcoin (outside TSP). Hold Bitcoin in personal accounts — self-custody, a Bitcoin IRA with a qualified custodian, or within a trust structure. This is where your Bitcoin allocation lives. The key insight: because your TSP provides guaranteed diversified equity exposure with employer match, you can afford to be more concentrated in Bitcoin in your non-TSP accounts than a private-sector employee who needs their entire retirement portfolio to be diversified.

FERS Pension + Bitcoin: The Guaranteed Income Advantage

Most Bitcoin estate planning guides assume the reader's entire financial future depends on portfolio performance. Federal employees under FERS have something most private-sector workers do not: a defined-benefit pension that pays a guaranteed annuity for life.

A FERS employee retiring at 62 with 30 years of service receives an annuity equal to 33% of their high-3 average salary (1.1% × 30 years). For a GS-15, Step 10 in a high-cost locality, that is roughly $55,000–$65,000 per year, indexed to inflation through COLA adjustments. Combined with Social Security, a FERS retiree may have $90,000–$120,000 in guaranteed annual income before touching the TSP or any other savings.

This changes the Bitcoin allocation calculus fundamentally. When your baseline expenses are covered by guaranteed income streams, the risk profile of your investment portfolio shifts. You can tolerate higher volatility in your non-TSP accounts because you are not relying on those accounts for monthly expenses in retirement.

Estate Planning Implications

The FERS annuity has specific estate planning features that interact with your Bitcoin plan:

• Survivor annuity. A FERS retiree can elect a survivor annuity for their spouse (25% or 50% of the retiree's annuity). This provides lifetime income for the surviving spouse independent of any Bitcoin or investment assets. If you elect the full survivor annuity, your spouse's baseline needs are covered, and Bitcoin held in trust can be designated for children, grandchildren, or charitable purposes without jeopardizing the surviving spouse's financial security.
• No asset to transfer. Unlike a TSP balance or Bitcoin holdings, the FERS annuity is not an asset that passes through your estate. It is an income stream that either continues (via survivor annuity) or terminates at death. You cannot leave your pension to a trust or to children who are not eligible survivors. This means your Bitcoin and TSP become the primary transferable wealth — making their estate plan structure even more critical.
• FEGLI and SGLI considerations. Federal Employees' Group Life Insurance (FEGLI) and Servicemembers' Group Life Insurance (SGLI) provide life insurance that can be designated to beneficiaries independent of your will or trust. Coordinate these beneficiary designations with your overall estate plan. A common error: naming your estate as FEGLI/SGLI beneficiary instead of individuals or a trust, which forces the proceeds through probate.

Conflict of Interest: 5 CFR 2635 and Bitcoin

The Standards of Ethical Conduct for Employees of the Executive Branch — codified at 5 CFR Part 2635 — permit federal employees to hold personal investments, including Bitcoin. There is no regulation prohibiting cryptocurrency ownership by government workers.

The restriction is on participation. Under 18 U.S.C. § 208 and 5 CFR 2635, Subpart D, a federal employee may not participate personally and substantially in any particular matter that would have a direct and predictable effect on their financial interest. For most federal employees, this is irrelevant — an IRS examiner auditing a construction company has no conflict with their personal Bitcoin holdings.

But for employees at certain agencies, the intersection is direct:

• SEC employees working on Bitcoin ETF approvals, cryptocurrency enforcement actions, or digital asset rulemaking may need to recuse from those matters — or divest their Bitcoin holdings.
• CFTC employees involved in Bitcoin futures regulation face similar recusal obligations.
• Treasury and FinCEN employees working on cryptocurrency reporting rules (such as the broker reporting requirements under the Infrastructure Investment and Jobs Act) cannot participate in those matters if they hold Bitcoin.
• Federal Reserve employees involved in CBDC policy or cryptocurrency banking guidance may face conflicts.
• OCC examiners reviewing bank custody of digital assets cannot participate if they hold the same assets personally.

The options for conflicted employees are recusal (step away from the matter), divestiture (sell the Bitcoin), or a waiver under 18 U.S.C. § 208(b). Waivers are rare and require a determination that the financial interest is not substantial enough to affect the employee's integrity. For a meaningful Bitcoin position, a waiver is unlikely.

The Hatch Act and Bitcoin Advocacy

The Hatch Act (5 U.S.C. §§ 7321–7326) restricts federal employees from engaging in political activity while on duty, in a government building, or using government resources. Does talking about Bitcoin on social media violate the Hatch Act?

Generally, no. Discussing Bitcoin as a personal investment, sharing market analysis, or expressing opinions about monetary policy and sound money are not political activities under the Hatch Act. The Hatch Act targets partisan political activity — campaigning for or against candidates, soliciting political contributions, and using official authority to influence elections.

However, the line can blur:

• Endorsing specific crypto legislation tied to a candidate's platform could be construed as partisan activity if done while on duty or using your official title.
• Promoting specific cryptocurrency companies while identifying yourself as a federal employee could raise both Hatch Act and ethics concerns.
• Using your official position to advocate for Bitcoin adoption in government operations crosses into misuse of position under 5 CFR 2635, Subpart G, regardless of Hatch Act analysis.

The practical guidance: keep your Bitcoin advocacy personal, off-duty, and separate from your official role. Do not use your GS title, agency affiliation, or official email when discussing cryptocurrency publicly. This protects both your Hatch Act compliance and your estate planning privacy — you generally do not want your official position publicly linked to your Bitcoin holdings.

Military-Specific Considerations

Active-duty military members face everything above plus deployment. A 12-month deployment to a combat zone or unaccompanied tour means you are physically unable to manage your Bitcoin for an extended period. No hardware wallet access. No exchange account management. No ability to respond to time-sensitive estate or tax matters.

For comprehensive military Bitcoin estate planning, see our complete military estate planning guide. Below are the deployment-specific Bitcoin considerations.

Pre-Deployment Key Distribution

Before deployment, self-custody Bitcoin holders must solve the access problem. If you are the only person who knows your seed phrase and you are killed in action, your Bitcoin dies with you. If you are incapacitated, no one can manage it on your behalf.

Pre-deployment key distribution should include:

• Successor trustee access. If your Bitcoin is held in a revocable living trust, ensure your successor trustee has the information and technical capability to access the Bitcoin. This means seed phrases, hardware wallet PINs, and exchange credentials must be documented and accessible — not just legally, but practically. See our self-custody inheritance guide for the technical framework.
• Multisignature arrangements. A 2-of-3 multisig setup — where you hold one key, your spouse holds one, and your estate attorney or a collaborative custody provider holds one — ensures access survives your absence or death without giving any single party unilateral control.
• Letter of instruction. A non-legal document left with your estate planning documents that provides step-by-step instructions for accessing, managing, and distributing your Bitcoin. This is especially critical for beneficiaries who are not technically sophisticated.

Power of Attorney for Cryptocurrency

A standard military power of attorney — even the broad general power of attorney executed during pre-deployment legal assistance — may not be sufficient for cryptocurrency management. Many exchanges and custodians require specific language granting authority over digital assets, cryptocurrency accounts, and blockchain-based holdings.

A crypto-specific durable power of attorney should explicitly grant authority to:

• Access and manage cryptocurrency exchange accounts
• Execute trades, transfers, and withdrawals of digital assets
• Access hardware wallets and cold storage devices
• Manage private keys and seed phrases
• Interact with DeFi protocols, staking services, and custodial platforms
• File tax returns related to cryptocurrency transactions
• Make estate planning decisions regarding digital assets, including transfers to trusts

Execute this during your pre-deployment legal readiness review at the installation's legal assistance office. Most JAG offices are now familiar with cryptocurrency POA language, but bring a template — do not assume they have one.

SGLI/VGLI and Bitcoin Estate Coordination

Servicemembers' Group Life Insurance (SGLI) provides up to $500,000 in coverage at subsidized rates. Veterans' Group Life Insurance (VGLI) continues coverage after separation. These policies pay directly to named beneficiaries — they do not pass through your will or trust unless you name your estate as beneficiary (which you should almost never do).

Coordinate SGLI/VGLI beneficiary designations with your Bitcoin estate plan. If your surviving spouse will inherit both the SGLI proceeds and your Bitcoin, ensure the trust structure accounts for both. If you want SGLI proceeds to fund a trust for minor children while Bitcoin goes to your spouse outright (or vice versa), the beneficiary designations must be intentional and consistent with the trust documents.

State Government Pension Protections vs. Bitcoin Exposure

State and local government employees have an additional consideration: pension protections. In most states, government pensions are fully exempt from creditor claims — protected by state constitution, statute, or both. A state employee with a $60,000/year pension cannot have that income garnished by most creditors (other than the IRS or for child support/alimony).

Bitcoin has no such protection. Bitcoin held in a personal wallet, on an exchange, or in a taxable brokerage account is fully exposed to creditor claims, lawsuit judgments, and bankruptcy proceedings. The irony: the government employee's most valuable asset (their pension) is bulletproof, while their Bitcoin — potentially worth far more — is completely exposed.

This creates a strong argument for holding Bitcoin inside an asset-protection trust structure. A properly structured irrevocable trust — such as a Domestic Asset Protection Trust (DAPT) in a favorable jurisdiction, or a Spousal Lifetime Access Trust (SLAT) — can provide creditor protection for Bitcoin that approximates the protection your pension already enjoys. Under the 2026 federal estate tax exemption of $15 million per person ($30 million for married couples), most government employees can transfer significant Bitcoin into irrevocable trusts without any gift tax liability.

Trust Strategies That Work Within Government Ethics Rules

Not every trust structure is compatible with federal ethics rules. The key question ethics officials will ask: does the trust arrangement genuinely separate you from the asset, or is it a transparency dodge?

Revocable Living Trust

A revocable living trust provides probate avoidance and incapacity planning but does not remove Bitcoin from your financial disclosure obligations or resolve conflict-of-interest issues. You are still the beneficial owner. The Bitcoin is still reportable. If you work at the SEC and hold Bitcoin in a revocable trust, you still have a conflict.

That said, a revocable living trust is still the foundation of any Bitcoin estate plan — it ensures your successor trustee can manage Bitcoin without court involvement if you die or become incapacitated. For deployment planning, it is essential. For a detailed comparison, see our trust vs. will guide.

Irrevocable Trust: The Ethics-Compatible Structure

An irrevocable trust — where you are neither trustee nor beneficiary and have no power to revoke, amend, or direct distributions — can genuinely remove Bitcoin from both your reportable assets and your conflict-of-interest analysis. This is the structure that resolves the SEC/CFTC/Treasury employee's dilemma.

However, the transfer must be genuine:

• You cannot serve as trustee
• You cannot be a beneficiary (your spouse and children can be)
• You cannot retain a power to revoke or amend
• You cannot direct the trustee's investment decisions
• The trust must have independent economic substance

Under the 2026 exemption of $15 million per person, a government employee can transfer substantial Bitcoin into an irrevocable trust — using a Spousal Lifetime Access Trust (SLAT) to benefit their spouse, or a dynasty trust to benefit children and grandchildren — with zero gift tax and complete removal from both the taxable estate and OGE disclosure forms.

The $19,000 annual gift exclusion for 2026 also allows systematic annual transfers to irrevocable trusts with Crummey powers, gradually moving Bitcoin out of your reportable portfolio over time.

Qualified Blind Trust

Senior officials may use a qualified blind trust under the Ethics in Government Act. Once approved by OGE, a qualified blind trust removes the reporting obligation for assets within the trust — the official genuinely does not know what the trust holds (the independent trustee manages all investment decisions). This is the gold standard for eliminating conflicts of interest, but it requires OGE approval, an independent trustee with no relationship to the official, and comes with significant administrative costs. It is primarily used by Cabinet-level officials and senior White House staff.

Case Study: Commander Sarah Mitchell, USN

Commander Sarah Mitchell is a Navy O-5 with 18 years of service, 12 years from retirement eligibility. She holds a TS/SCI clearance with CI polygraph for her assignment at a joint intelligence command. She owns 20 BTC acquired between 2017 and 2022, currently valued at approximately $2 million. Her husband is a civilian federal employee (GS-13) at the Department of Commerce. They have two children, ages 8 and 11.

The Constraints

• Security clearance. Sarah's Bitcoin holdings must be fully documented and consistent across her SF-86, tax returns, and financial records. Her next periodic reinvestigation is in two years. Any discrepancy between what she reported on her last SF-86 and her current holdings will require explanation.
• Financial disclosure. As an O-5 in a covered position, Sarah files OGE Form 450 (confidential disclosure). Her husband, as a GS-13, may or may not be a covered employee — depends on his position. If he is, his disclosure also captures community property or jointly held assets.
• Deployment risk. Sarah could be deployed with 30 days notice. She needs a plan that functions without her for 12+ months.
• Military pension integration. At 20 years of service, Sarah's military retirement annuity (under the Blended Retirement System if she opted in, or legacy High-3 if she did not) provides guaranteed income. With High-3, her annuity at O-5 with 20 years would be roughly $55,000–$60,000/year, with COLA.
• SGLI. $500,000 SGLI currently naming her husband as primary beneficiary.

The Estate Plan

Foundation: Revocable living trust. Sarah and her husband establish a joint revocable living trust. The trust holds their primary residence, investment accounts, and 10 BTC. The successor trustee is Sarah's sister — a civilian with no clearance obligations — who has been trained on hardware wallet access and multisig key management. A detailed letter of instruction accompanies the trust documents.

Bitcoin separation: Irrevocable SLAT. Sarah transfers 10 BTC (approximately $1 million) into a Spousal Lifetime Access Trust for her husband's benefit. This removes the Bitcoin from Sarah's taxable estate, her OGE 450 reportable assets, and her personal financial profile. Her husband can receive distributions from the SLAT if needed, maintaining family access to the Bitcoin without Sarah's direct ownership. The transfer uses $1 million of Sarah's $15 million lifetime exemption — leaving $14 million available for future transfers.

TSP strategy. Sarah maximizes TSP contributions to the Roth TSP option (no tax deduction now, but tax-free distributions in retirement). She allocates 80% C Fund, 15% S Fund, 5% I Fund — an aggressive equity allocation that she can tolerate because her military pension provides guaranteed baseline income. Her husband similarly maximizes his TSP under FERS, capturing the full 5% agency match.

Deployment preparation. Sarah executes a crypto-specific durable power of attorney granting her husband authority over all cryptocurrency accounts and digital assets. The 10 BTC in the revocable trust are held in a 2-of-3 multisig arrangement: Sarah holds key 1, her husband holds key 2, and their estate attorney holds key 3. Any two keys can execute a transaction. Pre-deployment, Sarah verifies that her husband can access the trust Bitcoin without her key (using his key plus the attorney's key).

SGLI coordination. Sarah's $500,000 SGLI names her husband as primary beneficiary and the revocable living trust as contingent beneficiary. If both Sarah and her husband die (e.g., in a common disaster), the SGLI proceeds fund the trust for the children's benefit rather than passing through probate.

Security clearance documentation. Sarah maintains a comprehensive cryptocurrency file: exchange records from 2017–2022, blockchain transaction records, tax returns showing all reported gains, current wallet addresses and balances, and a signed memo from her financial advisor confirming the acquisition timeline. This file is available for her next periodic reinvestigation and can be presented to investigators immediately upon request.

The Result

Sarah's estate plan satisfies every constraint simultaneously: clearance-compatible (all holdings documented), disclosure-compliant (reportable assets accurately reported, SLAT assets legitimately removed), deployment-ready (husband and attorney can manage without her), and estate-tax-optimized (SLAT removes Bitcoin from taxable estate with zero gift tax).

Practical Checklist: Bitcoin Estate Planning for Government Employees

1. Audit your disclosure obligations. Determine whether you file OGE 278e, OGE 450, or neither. Confirm your Bitcoin is properly reported on the correct form with accurate value ranges. If you've never reported it, correct the omission immediately through your DAEO — voluntary correction is always better than discovery during an investigation.
2. Document your acquisition history. Create a comprehensive file: exchange records, blockchain transactions, tax returns showing reported gains, and a written narrative explaining how you acquired your Bitcoin and when. This file protects you during clearance reinvestigations and estate administration.
3. Maximize TSP, hold Bitcoin separately. Do not wait for the TSP to add Bitcoin. Maximize your TSP contributions for the employer match and tax-advantaged growth, and hold Bitcoin in accounts outside the TSP — trusts, IRAs, or self-custody.
4. Establish a revocable living trust. Every government employee with Bitcoin needs, at minimum, a revocable living trust with a successor trustee who can manage digital assets. This is non-negotiable for deployment readiness and incapacity planning.
5. Evaluate irrevocable trust structures. If you have significant Bitcoin (above $500K), if you face recurring conflict-of-interest issues, or if disclosure privacy is a concern, work with an estate planning attorney to evaluate SLATs, dynasty trusts, or other irrevocable structures that legitimately remove Bitcoin from your reportable portfolio. The 2026 exemption of $15 million per person makes this the most favorable transfer environment in history.
6. Execute a crypto-specific power of attorney. A standard POA is not enough. Ensure your durable power of attorney explicitly covers digital assets, cryptocurrency accounts, private keys, and hardware wallets.
7. Coordinate beneficiary designations. FEGLI, SGLI, TSP, and any IRA accounts all pass by beneficiary designation — not through your will or trust. Review every designation annually and after any life change. Ensure they align with your overall estate plan.
8. Consult your DAEO. Before making any significant structural change to your Bitcoin holdings, consult your agency's Designated Agency Ethics Official. They can provide a written opinion on whether a proposed trust structure resolves disclosure and conflict-of-interest obligations. A written DAEO opinion is your strongest protection against future ethics challenges.

Frequently Asked Questions

Next Steps

Government employees who hold Bitcoin need an estate plan that satisfies two masters: the wealth preservation objectives that apply to every Bitcoin holder, and the disclosure, ethics, and operational constraints unique to public service. Neither can be ignored.

Start with our complete Bitcoin estate planning guide for the foundational framework. Then layer in the government-specific structures covered here. For military members, our military estate planning guide provides additional depth on deployment planning, survivor benefit coordination, and combat zone considerations.

A Bitcoin-literate estate planning attorney who understands both federal ethics rules and digital asset custody is not optional — it is the single most important hire you will make. Your DAEO can provide ethics guidance, but they are not estate planners. Your estate attorney can build trust structures, but they may not understand OGE forms. You need both, and they need to coordinate.

The 2026 federal estate tax exemption of $15 million per person represents a historically unprecedented window for transferring Bitcoin into irrevocable trusts. Whether this exemption persists beyond its current scheduled sunset remains subject to Congressional action. Government employees with significant Bitcoin positions should evaluate irrevocable trust transfers now, while the exemption allows multi-million-dollar transfers with zero gift tax.