Confiscating Bitcoin funds is different from actually accessing the funds in spendable form. I don't see clearly in the article where it says that the funds are in spendable form. Anyone that has a copy of the wallet - that might be secretly stored in a cloud on the Internet - and knows the passphrase, can access and spend the bitcoins.

Anyone who finds, steals or confiscates a Bitcoin wallet off a computer, and opens it with the kind of bitcoin program that created the wallet in the first place, can see the number of bitcoins that the wallet holds. They can calculate the value of the wallet. But if they don't have the wallet passphrase, they can't access the coins to use them to trade for fiat currency, or for anything else.

Passphrases are essentially long passwords. The greater the length of the passphrase, and the more random the characters and the variety of characters, the stronger the passphrase is. By the same token, the stronger the passphrase is like this, the harder it is to remember when using it to do business.

Now, if you don't write a long passphrase down, you just might forget it. If you DO write the passphrase down, somebody just might find it and access your coins. In extreme cases of Government abuse, even if you memorize the passphrase, Government just might get it out of you using truth serum (don't think that this is beyond them).

There are different ways for making and hiding complex passphrases that make them more difficult to find them, yet easier to "remember." Here is one method.

Use a random character generator to generate a long list of, say 10,000 random characters. The list might look something like this, only much, much longer:
  Pg0qzNeON4Sea5N9PBccdBpY0zL6Sk5DpAO3fKcmCZn0bkCzvPBNRjHaz3IFwvqUa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...

Next, select a small section from the list - fgzR5aoHABfzgvophdFiKwgm1XLYW0amgJ2BGY0sz1sAyKUlvYyRowRJFfdWJ0FCn - to use as your passphrase. Count the number of characters in your passphrase; in this case it is 65. Then, write down on a little piece of paper, the first 5 characters of the passphrase - fgzR5 - followed by the number 65 - fgzR565. This is your passphrase key. Hide several copies of your key, or memorize the whole thing and don't make any copies.

DO make multiple copies of the random character list. Make several computer files of it and several hard copies, and store them in several different places on different computers, and around the house and office. After all, this random character list holds your passphrase. If you lose it, you lose your passphrase - and all your bitcoins.

Whenever you want to access your passphrase, simply search for the first 5 characters of your passphrase key among the 10,000 random characters of the list. Those first 5, along with the following 60 characters, are your passphrase. In the unlikely event that the first 5 are duplicated exactly somewhere else in the list, you might have to search twice.

Odds are that nobody will be able to figure out your passphrase among all the possible combinations and sizes of passphrases in the random list. Yet you can access it easily with just the first 5 characters.