In a new legal advisory issued by the U.S. Office of Government Ethics (OGE) on June 18th, federal employees are now required to report their holdings of virtual currency. The guidance will affect around 2 million federal executive branch employees, including the Departments of Homeland Security, the Army, Justice, Veterans Affairs, and others.

The legal advisory also provided clarification on the definition of “cryptocurrency” stating that it is “property held … for investment or the production of income” as opposed to “real” currency or legal tender. Federal and executive branch employees are expected to report these holdings because they “may create a conflict of interest for employees who own it.” The OGE’s document also specifically makes mention of initial coin offerings or the sale of tokens prior to the launch of a particular network.

This new requirement is a bold stance for the Office but was deemed necessary because, “virtual currencies are experiencing a surge in use and access, and as a result, employees who hold virtual currencies are increasingly seeking guidance from their ethics officials concerning their financial disclosure reporting obligations.”

Read the full advisory here.