New Trust Bank Behind USD1, Largest Shareholder from Abu Dhabi

Is the Trump family starting a crypto bank? Will the issuance and redemption of USD1 change hands?

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 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 management of reserve assets for the stablecoin USD1.

Two weeks later, the public's attention shifted from what business the bank plans to conduct to who is funding this bank.

Equity Exposure: Abu Dhabi Capital Enters Bank's Holding Layer

On August 27, The Wall Street Journal cited sources revealing that Sheikh Tahnoon bin Zayed al Nahyan, the UAE National Security Advisor and a member of the Abu Dhabi royal family, along with co-investors, holds 49% of WLTC Holdings through StringZ Holding RSC; an entity associated with the Trump family holds another 38%.

It should be noted that the specific proportions of 49% and 38% come from interviews with sources by The Wall Street Journal, and the OCC documents do not disclose the exact shareholding ratios of each shareholder.

However, the OCC documents confirm two key facts in 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 various investors indirectly holding bank equity through this holding layer.

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

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

The Same Royal Family Member, Two Different Investment Vehicles

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

This means Tahnoon holds three identities: a royal family member, a senior government official, and a large capital manager. The investment landscape he manages or influences covers artificial intelligence, semiconductors, finance, energy, and digital assets, with MGX being a significant platform specifically investing in AI and advanced technologies.

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 disclosed that Tahnoon-supported Abu Dhabi investment vehicle Aryam Investment 1 plans to invest $500 million to acquire 49% of World Liberty Financial in January 2025. Of the initial $250 million payment, approximately $187 million flowed to entities controlled by the Trump family, and at least $31 million went to entities associated with the Witkoff family.

The Witkoff family comes from the U.S. real estate industry, with core figure Steve Witkoff being the founder of Witkoff Group and the current U.S. Special Envoy for Middle East Peace under the Trump administration, who was involved in the founding of World Liberty Financial. Project documents indicate that he was listed as a "retired 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.

An announcement from World Liberty Financial indicates that Zach Witkoff will also serve as the chairman of the WLTC board.

This bank investment utilized another entity, StringZ. In other words, Aryam Investment 1 corresponds to the previous investment in World Liberty Financial, while StringZ is used to hold the relevant equity in the WLTC bank holding company. Both are supported by the same member of the Abu Dhabi royal family but are not the same legal entity.

How Does a Passive Investment Commitment Restrict Shareholders?

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

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

It is also necessary to distinguish between two similarly named entities:

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

Both entities are associated with the Trump family but correspond to bank investments and the original business of World Liberty Financial, respectively, and should not be confused.

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

If any entity acquires 10% or more of a class of voting shares, more than 9.9% of the voting rights must be delegated 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 proportion of voting rights nor directly appoint directors or intervene in the bank's daily management. However, the passive investment commitment restricts control rights but does not automatically cancel investors' economic interests in share profits and asset appreciation.

What Kind of "Bank" is WLTC?

The business scope of World Liberty Trust Company, N.A. (WLTC) is significantly different from that of 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 stablecoin and digital asset services, rather than traditional deposit and loan services offered by ordinary commercial banks to retail customers. WLTC currently also does not plan to apply for a Federal Reserve master account and has committed not to issue, custody, or trade WLFI governance tokens.

Once it obtains final approval and officially opens, WLTC plans to conduct three core businesses:

• Issuing and redeeming USD1 for institutional clients across the U.S. and managing the reserve assets of USD1;
• Acting as a trustee for institutional clients to custody digital assets;
• Providing conversion services between approved stablecoins and USD1 for custody 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 its establishment, consolidating issuance, redemption, reserve management, and institutional custody into a trust bank directly regulated by the OCC.

However, WLTC cannot open for business yet. The OCC has only granted "preliminary conditional approval" and reserves the right to modify, suspend, or revoke this decision before 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 pre-opening inspections to obtain final approval.

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

On one side is the bank license, and on the other side are questions of conflicts of interest.

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

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

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

U.S. Senator Elizabeth Warren and others subsequently demanded that MGX, Binance, and World Liberty Financial provide relevant communication records and requested that the OCC suspend the bank license review of World Liberty Financial until Trump and his family divest their economic interests.

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

Regarding opinions on 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 are beyond the scope of this review. The OCC also stated that whether the Committee on Foreign Investment in the United States (CFIUS) reviews the equity and foreign investment of World Liberty Financial is also not within the scope of this license review; other policy concerns are not sufficient to constitute grounds for denying the application.

According to The Block, the White House denied that there were conflicts of interest in the transaction.

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

The bank license can limit how WLTC operates and can also constrain how shareholders exercise control. However, as long as the investment relationship is not fully disclosed, questions surrounding these shareholders will not automatically disappear with a mere approval.

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