Analysis of DOJ’s Bitcoin Sale and Compliance with Executive Order 14233

Title: DOJ’s Sale of Forfeited Bitcoin Sparks Controversy Amid Claims of Executive Order Violation

Date: January 6, 2025

In a surprising turn of events, the U.S. Department of Justice (DOJ) has come under scrutiny following reports that it sold approximately 57.55 Bitcoin (BTC) forfeited from Samourai Wallet co-founders Keonne Rodriguez and William Lonergan Hill. This sale, conducted through the U.S. Marshals Service (USMS), has raised questions about potential violations of President Donald Trump’s Executive Order 14233, which mandates that federal agencies retain forfeited Bitcoin as part of the U.S. Strategic Bitcoin Reserve.

Initial reports suggested that the DOJ’s actions could contravene this executive order, which aims to safeguard government-held Bitcoin. However, a closer examination of on-chain data reveals a more complex picture. While the Bitcoin was indeed transferred to Coinbase Prime custody, there is no definitive evidence on the blockchain indicating that the cryptocurrency was sold.

Understanding the On-Chain Data

On November 3, 2025, the 57.553 BTC was moved from a bech32 address linked to the Samourai forfeiture to a wallet identified as a Coinbase Prime Deposit. Shortly thereafter, the funds were swept into another Coinbase Prime wallet. Such internal transfers are standard operational procedures within Coinbase and do not imply a sale.

Further analysis indicates that the Bitcoin was consolidated within Coinbase’s extensive custody infrastructure, which encompasses thousands of addresses used for various operational purposes, including settlement and internal accounting. Notably, the blockchain does not show the Bitcoin leaving Coinbase-controlled infrastructure, raising questions about the claims of a sale.

No On-Chain Evidence of a Sale

The blockchain data fails to provide any indication that the Bitcoin was liquidated. Key points of analysis reveal that:

• The funds did not move to a non-Coinbase entity.
• There was no fragmentation into multiple outputs typical of trade execution.
• The Bitcoin did not flow into known exchange settlement wallets.
• There was no distribution pattern consistent with a completed sale.

A zero balance at the original Coinbase Prime deposit address merely indicates that the address was swept, a common practice for custodial platforms, rather than confirming liquidation.

The Executive Order Dilemma

Executive Order 14233 restricts the sale of “Government BTC” held in the U.S. Strategic Bitcoin Reserve. However, whether the forfeited Bitcoin from Samourai was ever formally transferred into Reserve-designated Treasury accounts remains unclear and cannot be determined solely from blockchain data.

To confirm any violation of the executive order, several pieces of documentation would be necessary, including:

• Court-issued forfeiture or disposition orders.
• USMS asset management records.
• Coinbase Prime execution and settlement documentation.

Unfortunately, none of these records are visible on-chain, leaving the matter shrouded in ambiguity.

Conclusion

While the DOJ’s handling of the forfeited Samourai Wallet Bitcoin has sparked significant debate, the current on-chain data does not substantiate claims of a sale. The question of compliance with Executive Order 14233 hinges on off-chain documentation and governance, leaving the crypto community and legal experts awaiting further clarification. As the situation unfolds, the implications for federal cryptocurrency policy and asset management remain to be seen.