The International Monetary Fund has approved an immediate disbursement of approximately $138 million to El Salvador after granting waivers for missed program conditions, including a zero ceiling on public-sector Bitcoin accumulation.

In an Oct. 1 statement, the IMF said its executive board completed the second and third reviews of the country's Extended Fund Facility arrangement. The decision unlocks 101.96 million Special Drawing Rights, roughly $138 million, under a 40-month program of about $1.4 billion approved on Feb. 26, 2025.

The fund based the waivers on "strong corrective measures and renewed commitments." Relief came with a renewed constraint on future purchases. "No further Bitcoin accumulation is envisaged beyond the documented donations," the board statement said.

The October statement does not specify how many bitcoins were involved in the breach.

Verified donations, no public funds

IMF staff said on Sept. 3, ahead of the board decision, that documentation verified Bitcoin accumulation since the first review reflected private donations. No public resources had been used, staff concluded.

The original program documents set a continuous ceiling of zero on voluntary Bitcoin accumulation by the public sector. They defined voluntary accumulation to include purchases and mining, while excluding holdings arising from law-enforcement measures such as seizures and forfeitures.

The program also required taxes to be paid only in U.S. dollars. It made private-sector acceptance of Bitcoin voluntary. And it called for the government to gradually unwind its participation in Chivo, the state-backed crypto wallet. Those conditions followed earlier negotiations over Bitcoin risks, which began drawing attention in August 2024.

The latest waiver lets financing proceed despite noncompliance. The IMF's accompanying statement still calls for limiting Bitcoin accumulation rather than unrestricted government buying.

Chivo transfer, residual exposure

On Chivo, the IMF reported that majority ownership and control had transferred to a private operator. Its September staff statement said the government retained a minority stake and custodial responsibilities for customer assets.

IMF First Deputy Managing Director Dan Katz welcomed the transfer in the October statement but said the "residual public-sector exposure should be fully unwound."

The fund also said fiscal consolidation had advanced broadly in line with program objectives. Reserve and liquidity targets were comfortably met.

Operational consequences

The waiver structure leaves the Bukele administration with a narrow lane for its Bitcoin holdings. The state can keep coins received through documented private donations and through seizures and forfeitures by law enforcement. Any purchase or mining output by public entities remains off the table for the life of the program.

The Chivo transfer marks the more consequential operational shift. Majority control now sits with a private operator, but the government's retained minority stake and its custodial role over customer assets keep the state exposed to the wallet's performance. The IMF has signalled it wants that exposure reduced to zero, which implies further divestment or restructuring before later reviews.

For private-sector participants in El Salvador, the program's design keeps Bitcoin acceptance voluntary and tax settlement dollar-only, cementing a two-tier arrangement in which the state holds Bitcoin but conducts fiscal operations in dollars.

The 40-month facility runs into 2028, and each remaining review gives the board a fresh opportunity to enforce the accumulation ceiling and the Chivo unwind — or grant another waiver if conditions slip again.