Trump family to open a crypto bank? Who will take over the issuance and redemption of USD1 and other businesses?

Written by: KarenZ, Foresight News

A preliminary conditional approval letter has brought the trust bank plan of World Liberty Financial to the forefront; two weeks later, the revealed equity structure has brought the Abu Dhabi royal capital into the spotlight.

On August 14, the Office of the Comptroller of the Currency (OCC) granted preliminary conditional approval for the establishment of World Liberty Trust Company, N.A. (WLTC). This national trust bank, still in the planning stage, aims to take over the issuance, redemption, and preparation asset management of the stablecoin USD1.

Two weeks later, public attention shifted from what businesses the bank planned to engage in to who was financing this bank.

Equity Exposure: Abu Dhabi Capital Enters Bank Control Layer

On August 27, The Wall Street Journal cited insiders disclosing that UAE National Security Adviser and Abu Dhabi royal member Sheikh Tahnoon bin Zayed al Nahyan (Tahnoon) and co-investors hold 49% of WLTC Holdings through StringZ Holding RSC; an entity connected to the Trump family holds another 38%.

It should be noted that the precise percentages of 49% and 38% come from The Wall Street Journal's interviews with insiders, and the OCC documents did not disclose the exact shareholding proportions of each shareholder.

However, the OCC documents confirmed two key facts about this structure:

First, the proposed WLTC will be wholly owned by the Delaware company WLTC Holdings LLC. WLTC is the entity applying for the national trust bank license, while WLTC Holdings is the holding company above the bank, with investors indirectly holding bank equity through this holding layer.

Second, StringZ Holding RSC (DE) LLC, DT Marks SC LLC, and AMGUS, LLC have indirect investments in the proposed bank and submitted passive investment commitments to the OCC.

Thus, this transaction involves at least two tiers: WLTC is responsible for applying for the license and operating the bank, while WLTC Holdings is responsible for holding WLTC and receiving investments from various shareholders.

The Same Royal Member, Two Different Investment Vehicles

Sheikh Tahnoon bin Zayed al Nahyan (Tahnoon) is the brother of UAE President Mohammed bin Zayed al Nahyan and currently serves as Deputy Ruler of Abu Dhabi and UAE National Security Adviser. He also chairs institutions like MGX, artificial intelligence group G42, Abu Dhabi Investment Authority (ADIA), and First Abu Dhabi Bank.

This means Tahnoon holds a triple identity as a royal member, senior government official, and major capital manager. His investment landscape spans artificial intelligence, semiconductors, finance, energy, and digital assets, with MGX being a significant platform for investments specifically in artificial intelligence and advanced technology.

Tahnoon's business relationship with World Liberty Financial can be traced back to before Trump's second inauguration. Earlier this year, The Wall Street Journal reported that the Abu Dhabi investment vehicle Aryam Investment 1, supported by Tahnoon, would spend $500 million in January 2025 to acquire 49% of World Liberty Financial. Of the initial $250 million payment, approximately $187 million flowed to entities controlled by the Trump family, with at least $31 million flowing to entities associated with the Witkoff family.

The Witkoff family is from the U.S. real estate sector, with key figure Steve Witkoff being the founder of Witkoff Group and also serving as the U.S. Special Envoy for Middle East Peace under the Trump administration. He was an early participant in the founding of World Liberty Financial. Project documents show that he was listed as "Honorary Co-Founder" of World Liberty Financial after entering government. His sons Zach Witkoff and Alex Witkoff are both co-founders of World Liberty Financial, with Zach currently serving as the company's CEO.

World Liberty Financial's announcement indicates that Zach Witkoff will also serve as Chairman of the WLTC Board.

This bank investment has utilized another entity, StringZ. This means Aryam Investment 1 corresponds to the previous investment in World Liberty Financial, while StringZ is used to hold the related equity stakes in the WLTC bank holding company. Both are supported by the same royal member from Abu Dhabi but are not the same legal entity.

A Passive Investment Commitment, How Does It Bind Shareholders?

The full name in the OCC documents is StringZ Holding RSC (DE) LLC. The OCC attachments indicate that the passive investment commitment from StringZ was signed by the company manager Hamad Khlfan Ali Matar Alshamsi.

DT Marks SC LLC, which appears with StringZ in the OCC documents, is an investment entity associated with the Trump family. The passive investment commitment of this company is signed by Trump's son Eric F. Trump in his capacity as President, directly confirming the management relationship between DT Marks SC and Eric Trump.

It is necessary to differentiate between two similarly named entities:

• DT Marks SC LLC appears in the WLTC bank approval documents as a direct or indirect investor in the proposed bank or its holding company.
• DT Marks DEFI LLC appears in prior legal disclosures from World Liberty Financial, holding about 38% of WLF Holdco LLC and possessing certain economic rights related to WLFI tokens and agreements.

Both entities are related to the Trump family, but correspond to banking investment and the original business of World Liberty Financial, and should not be confused.

The commitments submitted by StringZ, DT Marks SC, and AMGUS are fundamentally similar. All three companies are prohibited from seeking seats on the bank's board, obtaining significant non-public information, or influencing the bank's pricing, personnel, investments, and operating policies.

If any entity acquires 10% or more of a certain class of voting shares, over 9.9% of the voting rights must be entrusted to the bank's management.

This arrangement separates economic rights from operational control. Even if the 49% shareholding ratio disclosed by The Wall Street Journal is accurate, StringZ cannot obtain the same percentage of voting rights, nor can it directly appoint directors or interfere in the routine management of the bank. However, passive investment commitments limit control but do not automatically cancel investors' economic interests in share returns and asset appreciation.

What Kind of "Bank" is WLTC?

World Liberty Trust Company, N.A. (WLTC) will have a business scope that is clearly distinct from a typical commercial bank.

According to the OCC approval documents, WLTC will be a limited-purpose national trust bank without FDIC deposit insurance. Its business plan focuses on stablecoins and digital asset services rather than traditional deposit and loan businesses aimed at retail customers that typical commercial banks conduct. WLTC also does not plan to apply for a Federal Reserve master account and promises not to issue, custody, or trade WLFI governance tokens.

Once it receives final approval and officially opens, WLTC plans to engage in three core types of business:

• Issuing and redeeming USD1 for institutional clients across the U.S. and managing the reserve assets of USD1;
• Custodying digital assets for institutional clients in a fiduciary capacity;
• Providing conversion services for approved stablecoins and USD1 to custodial clients.

Currently, the exclusive issuer and custodian of USD1 is BitGo Bank & Trust. WLTC plans to take over the reserve assets and related liabilities of USD1 after establishment, consolidating issuance, redemption, reserve management, and institutional custody into a trust bank directly regulated by the OCC.

However, WLTC cannot open for business just yet. The OCC has only granted "preliminary conditional approval" and reserves the right to modify, suspend, or withdraw this decision prior to final approval.

WLTC must also maintain at least $20 million in tier 1 capital, establish compliant anti-money laundering, sanctions screening, and customer information security systems, submit a complete information system and operational structure, and pass a pre-opening inspection to obtain final approval.

If WLTC fails to raise sufficient capital within 12 months after preliminary approval, or fails to officially open within 18 months, this approval will essentially become invalid. World Liberty Financial also refers to this approval as a node in a multi-stage bank licensing process in its announcement.

On One Side is a Bank License, On the Other Side are Conflict of Interest Concerns

Tahnoon's connection to World Liberty Financial extends to Binance through USD1.

In March 2025, MGX, chaired by Tahnoon, announced an investment of $2 billion in Binance, acquiring a minority stake. MGX only indicated that the transaction was settled using a stablecoin, without disclosing the name of the stablecoin. On May 1, World Liberty Financial co-founder Zach Witkoff announced at the Token2049 conference in Dubai that MGX was using the then recently launched USD1. Bloomberg subsequently reported this news.

This transaction rapidly expanded the circulation of USD1 and led to intensified scrutiny of the relationship between Abu Dhabi capital, Trump family's economic interests, and U.S. cryptocurrency policy.

U.S. Senator Elizabeth Warren and others subsequently requested MGX, Binance, and World Liberty Financial to provide relevant communication records and also requested the OCC to suspend World Liberty Financial's bank license review until Trump and his family withdraw from the related economic interests.

The OCC responded in the approval documents to concerns about suspending or denying the application but still granted WLTC preliminary conditional approval. The documents stated that the application was reviewed by OCC career staff according to established procedures and relevant statutory, regulatory, and policy standards.

Regarding concerns over the purchase of WLFI tokens, potential conflicts of interest, and the U.S. Constitution's Compensation Clause, the OCC stated that since World Liberty Financial and its foreign investors are not parties to this bank license application, these issues fall outside the scope of this review. The OCC further indicated that whether the U.S. Committee on Foreign Investment in the United States (CFIUS) should review World Liberty Financial's equity and foreign investments is also outside the scope of this license review, and other policy concerns are not sufficient to warrant a denial of the application.

According to The Block, the White House denied the existence of conflicts of interest in the relevant transactions.

What needs to be observed next is whether the OCC will issue the final approval for opening, whether WLTC will disclose a more complete shareholder list, and how related transactions and profit distributions will be disclosed after the USD1 reserve assets transfer from BitGo to the new bank.

The bank license can limit how WLTC operates, but it can also constrain how shareholders exercise control. However, as long as the investment relationship has not been fully disclosed, questions around these shareholders will not automatically disappear with a simple approval.

What needs to be observed next is whether the OCC issues the final approval for opening, whether WLTC makes the complete shareholder list public, and how WLTC will disclose related transactions, shareholder returns, and potential conflicts of interest after the transfer of USD1 reserve assets from BitGo to the new bank.