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Intesa Sanpaolo revealed its Bitcoin holdings via ETF

Intesa Sanpaolo revealed its Bitcoin holdings via ETF through a U.S. regulatory disclosure for December 2025

Leila Al-Khatib

KEY POINTS

  • The bank reported roughly ninety-six million dollars across multiple spot bitcoin ETFs.
  • The largest positions appeared in ARK 21Shares Bitcoin ETF and iShares Bitcoin Trust.
  • This filing also listed a put option position tied to Strategy shares.
  • Smaller exposure included a Solana staking fund and several crypto-related equities.

A 13F filing for the quarter ending December 2025 outlined the bank’s U.S. reported positions.

I am looking at this disclosure because it appears to be the first time we have seen publicly disclosed the bitcoin exposures of a large European bank. The bank disclosed five different spot bitcoin exchange-traded funds (ETFs) totaling approximately $96 Million Dollars in total exposure. The largest of those disclosures was just over $72.6 Million Dollars exposure to ARK 21 Shares bitcoin ETF.

The next largest exposure disclosed was $23.4 Million Dollars in iShares Bitcoin Trust. These are examples of where the bank is using regulatory-approved “wrappers” to hold bitcoin versus directly holding the underlying asset itself. In my opinion, this shows large European banks are using “vehicles” they can understand, and therefore trust, to add exposure to bitcoin. Additionally, the same filing contained a much smaller exposure to a Solana fund tied to staking rewards. That Solana exposure was disclosed as approximately $4.3 Million Dollars in a Solana Staking ETF.


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Outside of exposure to the various funds, the filing lists many small equity stakes in companies related to the crypto space. Some names include Coinbase, Robinhood, BitMine, and ETHZilla, as well as Circle, which had the largest equity stake of approximately $4.4 Million Dollars. Those equity stakes were relatively small compared to the bank’s commitment to spot bitcoin ETFs reported in the same filing. There was another interesting detail in the filing. A “control” label was used and referred to as DFND, which means Shared Defined Investment Authority.

The use of the shared defined status indicates that the parent firm retains strategy oversight, but the affiliates execute the strategies. A separate filing by the U.S. wealth division of the bank showed that there was no exposure to digital assets during that reporting period.

Intesa Sanpaolo revealed its Bitcoin holdings via ETF

One of the more complicated lines in the filing involved options on Strategy, a large corporate holder of Bitcoin. As part of the same filing, the bank disclosed a significant put option position on Strategy shares. A put option is a contract that allows the buyer to sell shares later at a pre-determined strike price. Options structures such as this typically reflect either downside protection or a relative value trade against the bank’s exposure to Bitcoin. Strategy holds hundreds of thousands of Bitcoin, and Strategy stock is traded based on expectations of the company’s equity market performance.

Analysts follow Strategy mNAV, comparing enterprise value against the value of the company’s Bitcoin holdings. mNAV at Strategy reportedly peaked at about 2.9, then fell to approximately 1.221. When Strategy mNAV moves down, the price of Strategy shares usually moves closer to the value of the company’s Bitcoin holdings. Holding both a long position in spot bitcoin ETFs and a put option on Strategy would likely benefit if the premium for Strategy continues to compress. The combination of a long position in spot bitcoin ETFs with a Strategy put would allow for exposure to the potential upside in bitcoin, while providing protection against a re-rating of the company’s valuation.

This trade would also help to reduce the bank’s sensitivity to any company-specific risks associated with Strategy’s financing decisions. You, as an investor, should view the combined positions as evidence that the bank is actively managing risk versus simply speculating. The structure of this trade also illustrates how financial institutions separate their views on bitcoin prices from their views on the equity premium dynamic.


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The disclosure noted that the bank purchased Bitcoin directly last year. That earlier purchase included 11 Bitcoin worth approximately $1 million at the time of the purchase. Additionally, the bank has a proprietary trading desk that engages in cryptocurrency trading. Those facts provide context for why the bank’s U.S. report included a reference to spot bitcoin ETFs. However, a 13F filing is limited to only those U.S. reportable securities and does not account for all global holdings. Therefore, the filing provides a partial glimpse into the bank’s positioning, as opposed to a complete view of its balance sheet.

If you are tracking institutional adoption, focus on the size of each position, the vehicle selected, and the hedge structure employed. Look for increases in the bank’s exposure to spot bitcoin ETFs, as well as changes in the bank’s options exposure to Strategy.
Monitor whether shared defined authority shifts towards increased client-led execution over time. Another useful signal is whether the bank expands its crypto equity stakes beyond small exploratory allocations. Overall, the filing implies that Intesa Sanpaolo is accessing digital assets via multiple paths. Future filings will determine whether the bank is treating these positions as tactical or longer-term exposure.

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Why did Intesa Sanpaolo use ETFs instead of holding bitcoin directly?

Many institutions prefer regulated fund wrappers because custody, reporting, and governance become clearer. Spot bitcoin ETFs trade on established exchanges and settle through familiar brokerage systems. Compliance teams often prefer this structure because policies already cover similar listed funds. The 13F filing also creates a public trail, which supports stakeholder oversight. ETF shares also simplify position sizing, rebalancing, and portfolio reporting across affiliates. For you, the ETF route often signals measured exposure rather than operational experimentation. Funds such as ARK 21Shares Bitcoin ETF and iShares Bitcoin Trust also provide liquidity during market stress. Liquidity matters when risk teams require rapid adjustments without moving underlying bitcoin markets.

What does the Strategy put option suggest about the bank’s strategy?

A put option grants a right to sell Strategy shares at a set price before expiration. Such a position often reflects protection against downside in Strategy stock pricing. The filing also showed long exposure through spot bitcoin ETFs, creating a paired structure. This pairing suggests focus on the gap between Strategy equity value and bitcoin holdings value. Strategy mNAV tracks that premium by comparing enterprise value against bitcoin value. When the premium falls, Strategy shares often drop even when bitcoin holds steady. For you, this hedge highlights a sophisticated view, bitcoin exposure plus valuation risk control. The approach resembles relative value positioning rather than a single directional bet.

What does DFND shared defined authority mean for investors reading the filing?

DFND indicates shared defined discretion, meaning investment decisions involve more than one entity. The parent bank and affiliated managers share authority over the reported holdings. Execution often occurs through affiliates, while strategy oversight stays centralized. This structure appears common for large groups with multiple asset management units. For you, DFND suggests positions reflect a coordinated approach rather than a single portfolio manager. The label also means trades might serve proprietary objectives, client mandates, or a blend. Without additional disclosures, outsiders cannot assign exact intent to each affiliate. Still, DFND supports an interpretation of deliberate exposure design, not an accidental holding.

How should retail investors interpret the reported crypto equity and Solana exposure?

The filing showed smaller positions in crypto linked equities such as Circle, Coinbase, and Robinhood. Those stakes looked modest compared with the spot bitcoin ETFs allocation. Small sizing often signals exploration, diversification, or optional upside participation. The Solana staking fund position also appeared smaller than the bitcoin ETF basket. Staking linked exposure introduces different drivers, including network activity and staking reward rates. For you, these positions suggest a broad watchlist approach, where bitcoin remains primary. Equity holdings also carry business risks like regulation, competition, and revenue cycles. A diversified set of smaller lines reduces single name concentration while keeping exposure to sector themes.

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