While DCG, Genesis and other affiliated entities collectively own nearly 10% of the total shares outstanding of GBTC, they are only permitted to sell up to 1% of the total shares outstanding into the public markets every three months under Rule 144 of the Securities Exchange Act of 1933, according to Mr. Sonnenshein.

If Grayscale is unable to return capital to GBTC shareholders via a tender offer or ETF, the company currently plans to continue operating GBTC without a continuing redemption program until it succeeds in converting it into a spot bitcoin ETF, Mr. Sonnenshein said in the letter.