The username at the top of the dinner leaderboard is "Sun".
Written by: Leonardo Nicoletti, Anthony Cormier, David Kocieniewski
Translated by: Luffy, Foresight News
Among the major holders of the Trump meme coin, more than half come from foreign trading platforms that claim to ban U.S. users, indicating that many buyers are from outside the United States.
Trump is a cryptocurrency that was promoted by President Trump just days before his inauguration. Following an unprecedented promotional campaign, sales of the Trump token surged in the past two weeks: over 200 of the largest token holders will be invited to a dinner at Trump’s Virginia golf club on May 22, and the top 25 holders will qualify for an exclusive reception before the dinner and a "VIP" tour described on the Trump token website.
Currently, an analysis by Bloomberg shows that among the top 25 holders registered on the website leaderboard, all but 6 are using foreign trading platforms that claim not to accept U.S. residents. Among the top 220 holders on the leaderboard, at least 56% are using similar offshore trading platforms. The widespread presence of these potential foreign buyers echoes concerns from congressional Democrats about the ethical implications of promoting tokens in exchange for access to the president. It also raises questions about how participants in the promotional dinner will be scrutinized, as their public identities can only be linked to usernames consisting of a few letters.
Most major holders of the Trump token may be located outside the United States
The current value of tokens held by the 220 cryptocurrency wallets registered on the TRUMP leaderboard (based on the possible locations of the wallet holders). Of the tokens held by the top 220 wallets, 76% may belong to foreign owners, as these wallets are using trading platforms that U.S. residents cannot access.
Data source: Bloomberg's analysis of SolScan data.
(Note: Data is as of 10 AM Eastern Time on May 5. Usernames are listed on the TRUMP token website, set by wallet holders when registering for the dinner promotional event. One wallet that is still in the top 25 on the leaderboard is not listed here because it nearly sold off all its tokens on May 3.)
In the website's details, the organizers state that participants must undergo a background check. The website states: "We will also review your wallet for KYC and compliance purposes. You will dine with the President of the United States!" However, the website does not specify how such reviews will be conducted.
Promoters of the TRUMP token did not respond to requests for comment, nor did White House officials.
To appear on the dinner leaderboard, individuals who purchased TRUMP coins must register on the website, which claims to rank them based on the number of tokens held and the duration of holding, although many major holders have not yet registered. However, another analysis by Bloomberg of all major buyers (regardless of whether they are on the leaderboard) shows that more than half of this broader group of buyers also comes from foreign trading platforms.
It is possible that some U.S. buyers have found ways to circumvent the ban by using foreign trading platforms, such as using virtual private networks (VPNs) to hide their U.S. IP addresses. Most trading platforms state that they have taken measures, such as collecting user personal information, to try to prevent such circumvention. The three foreign trading platforms most commonly used by major holders of the TRUMP token to fund their accounts or purchase TRUMP coins are Binance, Bybit, and OKX, all of which have restrictions on U.S. users. Bloomberg's analysis found that before OKX launched its trading platform in the U.S. on April 15, there were 6 holders of the TRUMP token who made purchases on that platform. A spokesperson for OKX stated that prior to this, the company did not allow U.S. residents to make purchases. Representatives from Binance and Bybit did not respond to requests for comment.
Two of these three trading platforms had previously violated U.S. laws. In November 2023, Binance pleaded guilty to violating federal anti-money laundering and sanctions laws due to poor internal controls and paid over $4 billion to the U.S. OKX admitted in February to violating anti-money laundering regulations and paid over $420 million.
Cryptocurrency projects related to Trump have attracted a significant amount of foreign investors before.
Hong Kong cryptocurrency entrepreneur Justin Sun became an advisor to another cryptocurrency project promoted by the Trump family, World Liberty Financial (WLF), after announcing a purchase of tokens worth tens of millions of dollars. Sun stated at the time that he did not expect to receive any benefits from Trump due to this investment. According to Bloomberg's analysis of cryptocurrency wallet transactions, Sun may also be a major holder of the TRUMP token.
Justin Sun, founder of the blockchain platform Tron, in Hong Kong on May 8, 2020
Source: Bloomberg
World Liberty is promoting a stablecoin. One of the company's founders, Zach Witkoff, son of Trump’s Middle East envoy, announced at a conference on Thursday that this stablecoin will be used to facilitate a transaction between Binance and an investment company founded by the Abu Dhabi government. Executives from World Liberty did not respond to requests for comment.
Tony Carrk, executive director of the nonprofit Accountable.US, stated: "Congress should demand that the president disclose those who are secretly paying him off to assess whether the public interest is being harmed." The organization has set up a "Trump Accountability War Room" online. Accountable.US found that among the top 50 holders of World Liberty tokens, at least 14 also used cryptocurrency services inaccessible to Americans. Bloomberg's analysis found an additional 8 such wallets. World Liberty disclosed in November that its initial $300 million issuance was primarily sold overseas.
Many major holders of WLF tokens are located abroad
The holdings of the 50 wallets with the most WLF tokens (based on the possible locations of the wallet holders)
Data source: Accountable.US, Bloomberg's analysis of Etherscan data
Note: Data is as of 6:45 PM Eastern Time on April 30
Trump, who once called Bitcoin a "scam against the dollar," has delved deeper into the cryptocurrency space while his administration has begun to dismantle the regulatory and enforcement teams that were originally responsible for overseeing these digital assets. For example, shortly after he took office, staff at the U.S. Securities and Exchange Commission responsible for investigating cryptocurrencies were reassigned, and many of their cases were shelved. In April of this year, the U.S. Department of Justice disbanded its cryptocurrency task force.
Last month, Democratic Senators Adam Schiff and Elizabeth Warren called for the U.S. government's ethics office to investigate the Trump token dinner promotional event in a letter. They stated that the May 22 event poses "serious risks that President Trump and other officials may engage in corrupt behavior by selling opportunities for access to the president to individuals or entities, while personally profiting the president and his family."
The Trump family benefits from the rise in TRUMP token prices, as a company they control holds a significant amount of this token. Although the terms of the token issuance state that the Trump family cannot sell any tokens for a period of time, any fluctuations in price will change their wealth status on paper. The announcement of the April 23 dinner caused the token price to rise from about $9 to about $14, and in the following five days, there were 436 new transactions over $100,000, with the largest transactions involving accounts interacting with trading platforms not operating in the U.S.
A surge of foreign purchases followed the dinner announcement
Purchases of TRUMP tokens over $100,000 in April
Data source: Dune; Bloomberg's analysis of SolScan data
Note: Data is as of May 1
To qualify for dinner with Trump, token holders must register a "self-custody" wallet, which is fully controlled by the holder and not by a third-party trading platform.
Bloomberg analyzed the transactions of the top 220 wallets on the dinner leaderboard as of May 5 to determine whether their holders might be from abroad. Another separate analysis examined all self-custody wallets that held enough Trump tokens to qualify for the top 220 as of April 30. Many of the largest wallets are not listed on the dinner leaderboard, indicating that they have either not registered or their time-weighted holdings may differ significantly from their current holdings. Some may be strategically waiting to register.
While it is difficult to identify the individuals behind these accounts, there are already public clues about some of them. In recent days, entities on the leaderboard have been swapping positions, with at least one entity boasting about it online. A wallet named "MeCo" belongs to an entity called "Memecore," which claims to be a "multi-chain cross-staking mainnet compatible with the Ethereum Virtual Machine (EVM), secured by a Meme proof mechanism."
The company stated on the X platform: "We not only want to top the TRUMP leaderboard, but we also want to conquer the entire meme coin space." Memecore is asking users to send their TRUMP tokens to it to boost their rankings. The company stated that the tokens will be returned to users afterward, along with rewards.
Cherry Hsu, Memecore's Chief Business Development Officer, stated in a message on Telegram: "Currently, the meme coin space is considered stagnant, and we want to challenge that notion. By participating in this event, we want to show that the meme coin space is rising again."
According to Bloomberg's analysis of blockchain data, the leader that Memecore is chasing on the leaderboard chose the username "Sun" and is using a wallet associated with HTX, which is linked to Justin Sun. Sun himself has publicly acknowledged purchasing tokens from World Liberty Financial, but so far, he has not clarified whether he is the owner of the top wallet on the leaderboard. He did not respond to requests for comment.
The wallet marked "Sun" began accumulating tokens worth a total of $17.9 million when the Trump token was initially launched in January. Since the announcement of the Trump dinner promotional event, it has purchased an additional $4.5 million worth of tokens.
In 2023, the U.S. Securities and Exchange Commission sued Justin Sun, accusing him of orchestrating the issuance and sale of unregistered securities in collaboration with companies he owns and controls. Sun's lawyers denied the allegations, stating that the regulator's claims are "too far-fetched and should be dismissed." In February of this year, after Sun spent at least $75 million purchasing World Liberty Financial tokens, the SEC paused its lawsuit against him, stating that considering potential resolutions is in the interest of both parties.
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