The attorneys at a federal regulatory commission have drafted an opinion for Federal Election Commission consideration that approves the use of Bitcoins as campaign contributions in-kind.

The Office of the General Counsel at the FEC has drafted an advisory opinion that would permit the use of Bitcoins as in-kind contributions to campaigns and committees. The advisory opinion was requested by the Conservative Action Fund. The commission has posted the draft opinion for public comment until Nov. 13th. Some comments have already been filed.

The draft advisory opinion (AOR 2013-15) concludes that Bitcoins are not “money” within the meaning of FEC regulations, but that the requestor may generally accept Bitcoins as in-kind contributions under certain valuation, reporting and disbursement procedures. However the committee may not make disbursements using Bitcoins directly from a Bitcoin wallet because regulations require such disbursements to be made from a “campaign depository.” Instead the committee must sell its Bitcoins and deposit the proceeds in its campaign depositories before using the funds.