Crypto and World Liberty Financial

Updated2026-11-09 Covers2024-11 to 2026-11-07

Summary

In Trump’s second term, he and his sons started or grew several crypto businesses. They include World Liberty Financial (WLF), its WLFI token, its USD1 stablecoin (a crypto token built to keep a steady price), and the $TRUMP memecoin. At the same time, the administration issued orders on crypto policy. The Securities and Exchange Commission (SEC) dropped cases against crypto firms. Trump pardoned crypto executives. On Jan 16, 2025, a company linked to the national-security adviser of the United Arab Emirates (UAE) agreed to buy 49% of WLF for $500M. The purchase was not made public until February 2026.¹ The New York Times (NYT) reported on a later deal that let UAE groups import Nvidia chips. It said that deal came after the investment and went ahead even though U.S. national-security officials objected. The record shows the order of events. It does not show an agreement linking them.² Trump’s June 2026 disclosure shows more than $1B in crypto income for 2025.³ A lawsuit says the UAE payments are foreign emoluments, meaning payments from a foreign government that the Constitution forbids without Congress’s consent. The suit (Oct 22, 2026) has not been decided.⁴

Background

In May 2024 Trump promised the Libertarian National Convention that he would commute the sentence of Silk Road founder Ross Ulbricht. A commutation shortens a sentence but leaves the conviction in place. Per Public Citizen, crypto companies put about $119M into that election.⁵ Before Trump took office, the SEC was suing the crypto companies Coinbase, Binance and Kraken. The Justice Department (DOJ) also ran a National Cryptocurrency Enforcement Team (NCET).⁶,⁷

A federal conflict-of-interest law bars officials from acting on government matters that affect their own money (18 U.S.C. § 208). The President is exempt from it.⁴⁰ The legal rule that does apply to him is financial disclosure, meaning he must report his assets and income.⁸ The Constitution’s Foreign Emoluments Clause (Art. I, § 9, cl. 8)⁴¹ is a rule against officeholders taking payments or gifts from foreign governments. It bars them from accepting “any present, Emolument… of any kind whatever” from a foreign state unless Congress agrees.⁹ Trump kept his businesses. Many of his main assets are held in a revocable trust, one he can change or cancel, and Donald Trump Jr. oversees it.⁸

What happened

UAE investments, chips and the trust bank

On Jan 16, 2025, Eric Trump signed a deal for Aryam Investment 1 to buy 49% of WLF for $500M. Aryam is linked to Sheikh Tahnoon bin Zayed.¹ Of the first $250M, about $187M went to groups tied to the Trump family. About $31M went to groups tied to the family of envoy Steve Witkoff.¹ The public did not learn of the stake until the Wall Street Journal (WSJ) reported it on Feb 1, 2026.¹ WLF announced plans to launch USD1 in March 2025.¹⁹ On May 1, 2025, MGX used USD1 to pay for a $2B investment in Binance. MGX is a UAE fund backed by the state, and Tahnoon is its chair.²⁰ On Jun 11, 2025, the Senate voted down, 56–39, a resolution to block a ~$1.6B sale of helicopters to the UAE. The sponsor, Sen. Chris Murphy, tied the sale to the UAE crypto investment and to a “broader scheme which enriches Donald Trump.”⁶⁰ The NYT reported on Sept 15, 2025 about a deal that let UAE groups import hundreds of thousands of Nvidia chips. It said the deal came after the Tahnoon investment. It also said the deal went ahead even though national-security officials objected.² On Jul 10, 2026, a Commerce Department rule moved the UAE into its most favorable tier for export controls, which are limits on selling sensitive goods abroad. The rule let the UAE government and approved companies get advanced AI chips without a license.⁵⁶

On Jan 7, 2026, WLF asked the Office of the Comptroller of the Currency (OCC) for a trust charter, a license to run a kind of bank. The GENIUS Act makes the OCC the main federal regulator of stablecoin companies that qualify under federal rules. The OCC posted its conditional approval, which depends on further steps, on Aug 14, 2026.²⁸,²⁹ Per the WSJ, Tahnoon and his co-investors own 49% of the bank’s holding company, WLTC Holdings. They own it through StringZ Holding RSC. A Trump entity owns 38%.³⁰ That stake is separate from Aryam’s 2025 purchase of 49% of WLF itself.³⁰,¹

The $TRUMP memecoin

On Jan 17, 2025, Trump launched $TRUMP with a post on Truth Social.¹¹ Its price reached an all-time high of $75.35. Two companies together own 80% of the planned 1B-token supply: CIC Digital LLC, a Trump Organization affiliate, and Fight Fight Fight LLC.¹¹ On Feb 27, 2025, SEC staff stated that meme coins like this are not securities, the investments that securities laws cover. That staff view “has no legal force or effect.”⁴⁶ On May 22, 2025, Trump spoke under the presidential seal at a dinner for the coin’s top 220 holders. The dinner was at his golf club in Sterling, Virginia. Tron founder Justin Sun was the top holder. The White House said Trump attended “on his personal time,” and Public Citizen, citing Bloomberg, reports that 19 of the top 25 bought through foreign exchanges.⁴⁹ The coin’s manager, Fight Fight Fight LLC, held a second event for the top 297 holders at Mar-a-Lago on Apr 25, 2026. That day the coin traded just under $3. Sens. Warren, Schiff and Blumenthal asked the company for details.⁵⁵

Policy orders and legislation

On Jan 23, 2025, Executive Order 14178 put crypto policy under a working group led by David Sacks, the AI and crypto czar. An executive order is a written order from the President to the agencies he runs; it is not a law passed by Congress. This order barred a U.S. central bank digital currency. It revoked Biden’s EO 14067, and it also ordered a study of a “national digital asset stockpile.”³⁹ On Mar 2, 2025, Trump posted the names of coins for a crypto reserve. Within hours, crypto markets rose by roughly $300B.¹⁴ The Mar 6 order created the Strategic Bitcoin Reserve.¹⁵ The watchdog group Citizens for Responsibility and Ethics in Washington (CREW) found that White House officials held up to $2.35M in the named coins.¹⁶ The day after the order, Trump hosted crypto executives at the White House. CREW reports that a WLF co-founder was among those invited.⁴⁸ The GENIUS Act⁴³ (July 18, 2025) became the first federal law on stablecoins. It says payment stablecoins are not to be treated as securities or commodities.¹⁷ An Aug 7, 2025 order told the Labor Department and the SEC to open 401(k)s to digital assets. The order works through agency guidance. The duties of plan managers under the Employee Retirement Income Security Act (ERISA)⁴⁴, a federal law that makes them act in savers’ best interest, still apply.¹⁸

Enforcement retreat and pardons

Sun increased his stake in January 2025. About a month later, the SEC and Sun asked the court to pause his case.¹⁰ On Feb 21, 2025, Coinbase announced that the SEC would drop its case against the exchange. The SEC filed the agreement to dismiss on Feb 27, under Acting Chair Mark Uyeda. Under Uyeda and then Chair Paul Atkins, the SEC dropped or closed at least a dozen crypto-related cases and probes in 2025.⁶ On Mar 5, 2026 the SEC agreed to drop its case against Sun. In exchange, his company Rainberry would pay a $10M fine. Sun neither admitted nor denied the claims. The settlement, an agreement that ends a case without a ruling, needed a judge’s approval.⁶² On Apr 7, 2025, Deputy Attorney General Todd Blanche issued a memo stating that DOJ “is not a digital assets regulator.” The memo shut down the NCET. ProPublica later reported that Blanche held $159K–$485K in crypto when he signed it.⁷ Trump also pardoned crypto figures. A pardon forgives a federal crime and erases the penalties. He pardoned Silk Road founder Ross Ulbricht (Jan 21, 2025), BitMEX and its founders (Mar 27, 2025), and Binance founder Changpeng “CZ” Zhao (Oct 23, 2025).⁵,¹²,¹³ Binance hired a longtime friend of Donald Trump Jr. as a lobbyist to seek the CZ pardon. Trump said on 60 Minutes that he did not know who Zhao was. He later said, “I have no idea who he is.”¹³

WLFI token sales and Binance

Sun put $75M into WLF in two rounds (Nov 2024 and Jan 2025).¹⁰ Large buyers paid into sales of the WLFI token. Most of the money from those sales goes to a Trump entity. Aqua 1 Foundation announced a $100M purchase in June 2025. Reuters (Oct 28, 2025) tied it to Guren “Bobby” Zhou, who denies wrongdoing.⁵⁰,⁶⁷ In August 2025, ALT5 Sigma, a company listed on Nasdaq, bought 7.28B tokens for about $1.46B. Eric Trump rang Nasdaq’s opening bell and became an observer on the company’s board. WLFI began public trading on Sept 1, 2025 and peaked at $0.3313.⁵¹,⁶⁸ By Jun 30, 2026 the company, renamed AI Financial, valued its WLFI at $421M. That was a paper loss of about $1.04B (Public Citizen, citing Forbes and Bloomberg). In May 2026, holders had approved unlocking the founders’ tokens, including Trump’s. The four founder wallets moved 22.5B tokens into the vesting contract, which releases tokens over time, on May 19.⁵¹,⁶⁹ AI Financial’s WLFI holdings could be sold or moved starting Aug 12, 2026, according to an SEC filing cited by Public Citizen.⁷⁰ After the CZ pardon, Binance ran USD1 and WLFI promotions with WLF. By Apr 21, 2026 Binance held about $3.56B of the $4.25B in USD1 outstanding (about 84%).⁵² Fortune reported that, from March 2024 to August 2025, groups linked to Iran had received more than $1B through Binance. The WSJ reported in March 2026 that DOJ had opened an investigation into Iran’s use of Binance to get around sanctions, the government penalties that freeze assets and bar dealings.⁵²

Pakistan and other family ventures

Pakistan’s crypto council signed an agreement with WLF in April 2025. Reuters reported on Jan 14, 2026, citing a source, that Pakistan’s government had agreed to use WLF’s USD1 stablecoin.²¹,⁶⁶ In between, Trump hosted army chief Asim Munir for a private White House lunch (June 18, 2025). The annex of the Jul 31, 2025 reciprocal-tariff order set Pakistan’s tariff at 19%. A tariff is a tax on goods coming into the country, paid by the importer. Trump doubled India’s tariff to 50% (Aug 6, 2025), citing its purchases of Russian oil.²¹,⁶⁴,⁶⁵,²² In January 2026 Witkoff’s WLF stake was sold to his sons. His disclosure, released in March 2026, showed that he partly owned SC Financial Technologies. That company is the WLF affiliate in the Pakistan agreement.⁵⁴ The family also took American Bitcoin public through a merger with Gryphon Digital (Sept 3, 2025).²³ Trump Media announced a ~$2.5B bitcoin treasury, a store of bitcoin held by the company (May 27, 2025).²⁴

Earnings, losses and lawsuits

The totals differ by source. The WSJ estimated about $1B in 2025 token-sale profits (Dec 2025). Reuters put the family’s gains at $2.3B or more.²⁵ Trump’s June 30, 2026 disclosure showed more than $1B in 2025 crypto income. That included $524M from WLF tokens.³ Public Citizen also counts USD1 revenue and sales of ownership stakes in WLF. It puts the total at $1.4B or more.⁵⁸ On July 4, 2026, the NYT reported that nearly a million buyers of the $TRUMP memecoin had lost a combined $3.81B through the end of June. Trump, meanwhile, took a $636M payout from the coin. The NYT also reported that a Trump entity collected 75% of WLFI sales after certain expenses. World Liberty said WLFI’s drop was due to broader market conditions.²⁶ Public Citizen estimated on Aug 27, 2026 that buyers of Trump-family crypto products were at least $4.7B underwater. That means their holdings were worth that much less than they paid. Much of the loss was unrealized, meaning the buyers had not sold. It included $3.2B in $TRUMP.⁵⁹,⁷²

Sun sued WLF in April 2026, accusing it of extortion.²⁷ On Nov 2, 2026 Sun asked Judge James Donato to make WLF and its lawyers pay $263,821.20 as a penalty. WLF’s first court filing had listed Florida as its only home. An Aug 26 filing listed 22 owners, including some in the UAE. A foreign party on both sides can keep a federal court from hearing a case, so WLF now argues the court cannot hear this one. Sun’s lawyers said the timing “smacks of gamesmanship.” A hearing is set for Dec 10.⁷³ On Oct 22, 2026, Circle shareholder J. Benjamin Greenberg filed a suit over the UAE deals under the Foreign Emoluments Clause. The case is Greenberg v. Trump (D.D.C.)⁴⁵, in the federal trial court in Washington, D.C. It names Trump, WLF and Witkoff.⁴ It calls Aryam’s purchase and MGX’s use of USD1 “unconstitutional emoluments.” It asks for the profits.⁴ WLF’s lawyer, Bill Burck, called it “more like a partisan press release than a lawsuit,” and the White House called it frivolous, meaning without merit. Circle said it had not authorized the suit.⁴

Key dates

• 2025-01-16 — Secret 49% WLF sale to Tahnoon vehicle — → ledger
• 2025-01-17 — $TRUMP memecoin launch — → ledger
• 2025-01-23 — EO 14178 crypto working group — → ledger
• 2025-02-21 — SEC drops Coinbase case — → ledger
• 2025-03-06 — Strategic Bitcoin Reserve order — → ledger
• 2025-04-07 — Blanche memo disbands NCET — → ledger
• 2025-05-01 — USD1 settles MGX’s $2B Binance investment — → ledger
• 2025-07-18 — GENIUS Act signed — → ledger
• 2025-09-15 — NYT links UAE chips to WLF — → ledger
• 2025-10-23 — CZ pardon — → ledger
• 2026-01-07 — WLF trust charter application — → ledger
• 2026-02-01 — WSJ reveals Tahnoon stake — → ledger
• 2026-04-22 — Justin Sun sues WLF — → ledger
• 2026-06-30 — Disclosure shows $1B+ crypto income — → ledger
• 2026-07-10 — Commerce moves the UAE into its most favorable export tier — → ledger
• 2026-08-14 — OCC conditional trust-bank approval; WLTC ownership — → ledger
• 2026-10-22 — Greenberg v. Trump emoluments suit — → ledger

Why it matters

Foreign Emoluments Clause (Art. I, § 9, cl. 8). This clause bars the President from taking payments from foreign governments unless Congress consents. The legal question is whether two payments count as emoluments “from any… foreign State” to the President. One is Aryam’s $500M. The other is MGX’s $2B, settled in USD1. They came from a company linked to a UAE official and from a fund backed by the UAE state. The money went to a company Trump owns through a revocable trust overseen by Donald Trump Jr.¹,²⁰,⁸,⁹ Congress has not voted to consent to either payment. Greenberg v. Trump makes that argument in court. The same question comes up at the $TRUMP holder events, if foreign buyers are among those given access to the President.⁴⁹,⁵⁵ The record here does not include the administration’s stated legal reason for treating the payments as allowed under the Clause. Standing comes first: the court must decide whether the plaintiff has a real injury that gives him the right to sue. The 2017–21 emoluments suits against Trump ended without a ruling on the merits, meaning no court decided whether he broke the Clause.⁴ The NYT reported that Witkoff worked on the UAE chips talks. It also reported that his son Zach helped arrange the MGX deal (see Gulf States, Israel and Gaza and Trump Organization Foreign Deals).²

Conflict-of-interest law (18 U.S.C. § 208). This law makes it a crime for officials to take part in decisions that affect their own money. The President is exempt from § 208, so the binding rule for him is financial disclosure.⁸ How the disclosure rules have applied to his personal stock trading is covered in Cabinet Financial Disclosures and Ethics Complaints#The President’s own trading. Other officials are covered. Ethics lawyers Virginia Canter and Kedric Payne told ProPublica that Blanche’s Apr 7 memo broke § 208 and his ethics agreement. That agreement required him to divest, or give up, his holdings within 90 days of his March 2025 confirmation. He divested in late May–June 2025, mostly by transferring the holdings to adult children and a grandchild. DOJ declined to comment.⁷ Section 208 reaches an official’s own interests and those of a spouse and minor children. It does not reach adult sons. So the sale of Witkoff’s WLF stake to his sons leaves a question open. It is not settled whether any conflict rule reaches the family’s continuing interest in a venture whose foreign partners he deals with as envoy.⁵⁴,⁴⁰ The record shows no finding on officials’ holdings of the reserve coins by an inspector general (an agency’s internal watchdog) or by the Office of Government Ethics (OGE).¹⁶ OGE reviews the disclosures of the President and his appointees. It has had no confirmed director since Trump removed Director David Huitema in February 2025. Trump nominated Michael Chamberlain on Jun 23, 2026, and OGE reports no Senate confirmation through Nov 6, 2026 (see Cabinet Financial Disclosures and Ethics Complaints and Inspectors General and Watchdogs).³¹,⁶³

Pardon power (Art. II, § 2, cl. 1).⁴² The Constitution gives the President power to grant pardons for federal crimes. Press secretary Karoline Leavitt announced the CZ pardon in a statement.¹³ A June 2026 Reuters review found that 96% of Trump’s clemency grants did not meet DOJ guidelines. Clemency includes pardons and shortened sentences. Congressional Democrats opened a “pay-to-play” inquiry covering the CZ grant on May 7, 2026 (see Pardons and Clemency).³⁴,³⁵

GENIUS Act (12 U.S.C. ch. 56) and securities law (SEC v. W.J. Howey Co.). The GENIUS Act is the federal law on stablecoins. Under it, the OCC is the main regulator of stablecoin companies that qualify under federal rules. The OCC has conditionally approved a trust bank owned in part by the Tahnoon group and in part by a Trump entity. The approval requires “passivity commitments” from both, which are promises to stay passive owners.²⁸,²⁹,³⁰ Sen. Elizabeth Warren promised a bill to bar presidents and senior officials from owning banks. WLF CEO Zach Witkoff said, “We welcome continuous scrutiny from Federal regulators for many years to come.”²⁹,³⁰ Under Atkins, the SEC started four enforcement actions against public companies in fiscal 2025. CFO Dive described a report by Cornerstone Research and NYU. Per that account, the outgoing chair saw the highest total since FY 2013, and the incoming chair saw the lowest. The Commodity Futures Trading Commission (CFTC) ran with one of its five commissioners, Michael Selig, from his swearing-in on Dec 22, 2025 through at least April 2026.³²,³³,⁷¹ The SEC staff’s meme-coin statement applies SEC v. W.J. Howey Co. (1946), a Supreme Court case. Under that case, an investment contract is an investment of money in a common enterprise, or shared venture, with profits to come from the work of others. The staff found that meme-coin buyers do not rely on others’ management work. It left fraud to other agencies. CREW lists the statement among Trump’s conflicts of interest. CREW noted that the SEC said “it won’t regulate memecoins like $TRUMP, which Trump launched days before his inauguration.”⁴⁶,⁴⁷

Sanctions, export-control and arms-sale statutes (IEEPA; 50 U.S.C. § 4811; 22 U.S.C. § 2776(b)). Binance’s 2023 guilty plea covered sanctions violations involving Iran. Deals with Iran fall under the Iranian Transactions and Sanctions Regulations (31 C.F.R. part 560). Those rules were issued under the International Emergency Economic Powers Act (IEEPA), a law that lets the President restrict trade with other countries in a declared national emergency. No outcome has been reported for the reported DOJ probe or for Sen. Blumenthal’s inquiry.⁵²,⁵³ Under the Export Control Reform Act of 2018 (50 U.S.C. § 4811 et seq.), Commerce sets each country’s export-control group by rule. It does not need Congress’s approval. The Jul 10, 2026 rule cited the UAE’s status as a “Major Defense Partner” and its “matching investments” commitment.⁵⁶,⁵⁷ Under the Arms Export Control Act (22 U.S.C. § 2776(b)), Congress can stop an arms sale it has been told about. It can do so only by enacting a joint resolution of disapproval into law. That was the tool used in the Jun 11, 2025 UAE vote.⁶⁰,⁶¹

Outcome

Where things stand

As of Nov 8, 2026, the ventures still operate and pay the family. The dismissed SEC cases have not been revived. The pardons stand.³,¹⁰ The OCC’s Aug 14, 2026 approval is still conditional. A final charter requires capital and an exam before opening (American Banker). It also requires “passivity commitments” from the Trump and Tahnoon entities.²⁹,³⁰ Congress has not voted on the UAE payments. The UAE has had access to advanced chips without a license since Jul 10, 2026.⁶⁰,⁵⁶

What is still moving is in court and in Congress. Greenberg v. Trump, Sun’s suit and WLF’s countersuit have no rulings on the merits. The reported DOJ investigation into Binance and Iran has no reported outcome. The congressional letters on the CZ pardon and on David Sacks have produced no published findings.⁴,³⁸,⁵²,³⁵,³⁶ On Nov 5, 2026 Sen. Richard Blumenthal, incoming chair of the Permanent Subcommittee on Investigations, renewed his requests for records from WLF, Fight Fight Fight LLC, Binance and Tether. He set a Jan 4, 2027 deadline.⁷⁴ Democrats take control of both chambers, with subpoena power (the power to order people to hand over documents or testify), on Jan 3, 2027.³⁷

Status

Who is affected

The events reach the Trump family, whose June 2026 disclosure shows more than $1B in 2025 crypto income. They reach the Witkoff family through payments from World Liberty Financial (WLF) and the stake purchase linked to the United Arab Emirates (UAE).³,¹ They reach buyers of the WLFI token, the $TRUMP memecoin and ALT5 Sigma stock through price drops that the New York Times (NYT) and Public Citizen measured. They reach top $TRUMP holders through access to the President at holder events.²⁶,⁵⁹,⁵¹,⁴⁹ They reach crypto firms and executives through Securities and Exchange Commission (SEC) dismissals and pardons. They reach the UAE government and approved companies through access to advanced chips without a license.¹⁰,¹³,⁵⁶

• Trump family (WLF, USD1, $TRUMP and other family ventures, In force) — the Jun 30, 2026 disclosure showed more than $1 billion in 2025 crypto income, including $524 million from WLF tokens. Public Citizen puts it at $1.4 billion or more. The Wall Street Journal (WSJ) estimated about $1 billion in 2025 token-sale profits (Dec 2025). Reuters put family gains at $2.3 billion or more.³,⁵⁸,²⁵
• Trump and Witkoff families: UAE stake (49% of WLF sold to Aryam Investment 1 Jan 16, 2025; Greenberg v. Trump Pending) — of the first $250 million, about $187 million went to groups tied to the Trump family. About $31 million went to groups tied to envoy Steve Witkoff’s family. The suit filed Oct 22, 2026 asks for the profits.¹,⁴
• $TRUMP and WLFI buyers (family ventures, In force) — the NYT reported Jul 4, 2026 that nearly a million $TRUMP buyers had lost $3.81 billion through the end of June. It reported that a Trump entity collected 75% of WLFI sales after certain expenses. World Liberty said WLFI’s drop was due to broader market conditions.²⁶
• ALT5 Sigma shareholders (family ventures, In force) — the company paid about $1.46 billion for 7.28 billion WLFI tokens in Aug 2025. By Jun 30, 2026 the company, renamed AI Financial, valued them at $421 million. That was a paper loss of about $1.04 billion (Public Citizen, citing Forbes and Bloomberg).⁵¹,⁷⁰
• $TRUMP buyers (family ventures, In force) — the coin reached an all-time high of $75.35 after its Jan 17, 2025 launch. CIC Digital LLC, a Trump Organization affiliate, and Fight Fight Fight LLC together own 80% of the supply. The coin traded just under $3 on Apr 25, 2026.¹¹,⁵⁵
• Buyers of Trump-family crypto products overall (family ventures, In force) — Public Citizen estimated Aug 27, 2026 that buyers were at least $4.7 billion underwater, much of it unrealized (not yet sold). That included $3.2 billion in $TRUMP.⁵⁹,⁷²
• Top $TRUMP holders (family ventures, In force) — Trump spoke at a May 22, 2025 dinner for the top 220 holders. 19 of the top 25 holders bought through foreign exchanges (Public Citizen, citing Bloomberg). The White House said he attended “on his personal time.” A second event for the top 297 holders was held Apr 25, 2026.⁴⁹,⁵⁵
• Crypto firms facing SEC cases (SEC crypto dismissals, Concluded) — at least a dozen crypto-related cases and probes were dropped or closed in 2025, including Coinbase’s (announced Feb 21, 2025, agreement filed Feb 27). The SEC agreed Mar 5, 2026 to drop Justin Sun’s case for a $10 million fine paid by his company Rainberry, if a judge approves. Cornerstone Research counted four SEC enforcement actions against public companies started under Atkins in fiscal 2025, which per CFO Dive’s account was the lowest total for a chair since FY 2013.¹⁰,⁶,⁶²,³²
• Pardon recipients (crypto pardons, Concluded) — Trump pardoned Ross Ulbricht Jan 21, 2025, BitMEX and its founders Mar 27, 2025, and Binance founder Changpeng Zhao Oct 23, 2025. A June 2026 Reuters review found that 96% of Trump’s clemency grants did not meet Justice Department guidelines.⁵,¹²,¹³,³⁴
• UAE government and approved companies (UAE export-control tier, In force) — they have had access to advanced AI chips without a license since Jul 10, 2026. The NYT reported Sept 15, 2025 on an earlier deal letting UAE groups import hundreds of thousands of Nvidia chips. It said that deal came after the Tahnoon investment and went ahead even though national-security officials objected.⁵⁶,²

Key players

• Donald Trump — President (2025–) — launched $TRUMP, signed the reserve order and the GENIUS Act, and issued the crypto pardons.¹¹,¹⁵,¹⁷,¹³
• Eric Trump — WLF executive — signed the Tahnoon deal; became a board observer at ALT5 Sigma (Aug 2025).¹,⁵¹
• Steve and Zach Witkoff — envoy and WLF co-founder — their family received ~$31M from the UAE stake.¹
• Sheikh Tahnoon bin Zayed — UAE national-security adviser, chairs MGX — bought 49% of WLF (2025); his group holds 49% of WLTC Holdings, the trust bank’s parent company (2026).¹,³⁰
• Justin Sun — Tron founder — invested $75M (Nov 2024 and Jan 2025), had his SEC case paused and then settled for a $10M fine (Mar 2026), later sued WLF.¹⁰,⁶²,²⁷
• J. Benjamin Greenberg — Circle shareholder — filed an emoluments suit over the UAE deals (Oct 22, 2026).⁴
• Changpeng Zhao — Binance founder — pardoned (Oct 23, 2025); Binance later held about 84% of USD1 outstanding.¹³,⁵²
• Guren “Bobby” Zhou — tied by Reuters to Aqua 1’s $100M WLFI purchase — denies wrongdoing.⁵⁰,⁶⁷
• Sen. Chris Murphy — Senator — sponsored the failed resolution to block a UAE arms sale, citing the crypto investment (Jun 11, 2025).⁶⁰
• Paul Atkins — SEC Chair — oversaw the crypto dismissals after Acting Chair Mark Uyeda.⁶
• Todd Blanche — Deputy Attorney General (confirmed March 2025) — signed the memo shutting down the NCET; ProPublica reported he then held $159K–$485K in crypto.⁷

Chronology

• 2024-11 — Justin Sun invests $30M in WLF, $75M by Jan 2025 — → ledger
• 2025-01-16 — Secret 49% WLF sale to Tahnoon vehicle — → ledger
• 2025-01-17 — $TRUMP memecoin launch — → ledger
• 2025-01-21 — Ulbricht pardon — → ledger
• 2025-01-23 — EO 14178 crypto working group — → ledger
• 2025-02-10 — OGE director removed — → ledger
• 2025-02-21 — SEC drops Coinbase case — → ledger
• 2025-02-27 — SEC staff: meme coins not securities — → ledger
• 2025-03 (approx) — USD1 launch plans announced — → ledger
• 2025-03-02 — Crypto reserve post moves markets — → ledger
• 2025-03-06 — Strategic Bitcoin Reserve order — → ledger
• 2025-03-07 — White House crypto summit — → ledger
• 2025-03-27 — BitMEX pardons — → ledger
• 2025-03-31 — American Bitcoin announced — → ledger
• 2025-04-07 — Blanche memo disbands NCET — → ledger
• 2025-04 (late) — Pakistan–WLF deals — → ledger
• 2025-05-01 — USD1 settles MGX’s $2B Binance investment — → ledger
• 2025-05-12 — $TRUMP holders’ dinner (held May 22) — → ledger
• 2025-05-27 — Trump Media bitcoin treasury — → ledger
• 2025-06 — Aqua 1 announces $100M WLFI purchase — → ledger
• 2025-06-11 — Senate rejects blocking Qatar and UAE arms sales — → ledger
• 2025-06-13 — First annual disclosure — → ledger
• 2025-06-18 — Trump hosts Pakistan army chief Asim Munir — → ledger
• 2025-07-18 — GENIUS Act signed — → ledger
• 2025-07-31 — Reciprocal-tariff order sets Pakistan at 19% — → ledger
• 2025-08 — ALT5 Sigma’s $1.5B WLFI treasury raise — → ledger
• 2025-08-06 — India tariff doubled — → ledger
• 2025-08-07 — 401(k) crypto order — → ledger
• 2025-09-01 — WLFI begins public trading — → ledger
• 2025-09-03 — American Bitcoin lists on Nasdaq — → ledger
• 2025-09-15 — NYT links UAE chips to WLF — → ledger
• 2025-09-16 to 2026-04-21 — Binance, Iran sanctions questions and USD1 — → ledger
• 2025-09-30 to 2026 (mid) — SEC enforcement collapse — → ledger
• 2025-10-23 — CZ pardon — → ledger
• 2025-10-28 — Reuters ties Aqua 1 to Guren “Bobby” Zhou — → ledger
• 2025 (late) — Sacks conflicts — → ledger
• 2025-12 (mid) — WSJ crypto profit tallies — → ledger
• 2025-12-22 to 2026-04-26 — Single-commissioner CFTC — → ledger
• 2025-12-22 — Michael Selig sworn in as sole CFTC commissioner — → ledger
• 2026-01 — Witkoff’s WLF stake sold to his sons — → ledger
• 2026-01-07 — WLF trust charter application — → ledger
• 2026-01-14 — Pakistan agrees to use WLF’s USD1 stablecoin — → ledger
• 2026-02-01 — WSJ reveals Tahnoon stake — → ledger
• 2026-03-05 — SEC agrees to drop Sun case for $10M fine — → ledger
• 2026-04-22 — Justin Sun sues WLF — → ledger
• 2026-04-25 — Second $TRUMP holders’ event, at Mar-a-Lago — → ledger
• 2026-05-19 — WLF founders move 22.5B WLFI into vesting contract — → ledger
• 2026-06-04 — Reuters clemency review, pay-to-play probe — → ledger
• 2026-06-23 — Chamberlain nominated as OGE director — → ledger
• 2026-06-30 — Disclosure shows $1B+ crypto income — → ledger
• 2026-07-04 — NYT: $TRUMP buyers lose $3.81B — → ledger
• 2026-07-10 — Commerce moves the UAE into its most favorable export tier — → ledger
• 2026-08-12 — AI Financial’s WLFI tokens become transferable — → ledger
• 2026-08-14 — OCC conditional trust-bank approval; WLTC ownership — → ledger
• 2026-08-20 — Judge Donato keeps Sun’s individual claims in open court (per Sun) — → ledger
• 2026-08-27 — Public Citizen: buyers $4.7B underwater — → ledger
• 2026-10-22 — Greenberg v. Trump emoluments suit — → ledger
• 2026-11-02 — Sun asks court to penalize WLF over late disclosure of UAE owners — → ledger
• 2026-11-05 — Blumenthal renews records requests to WLF, Fight Fight Fight, Binance and Tether — → ledger

• 2026-11-07 — Democrats will control both chambers on Jan 3, 2027 — → ledger

• 2026-11-09 — Trump Media quarterly filing: revenue up 205%, driven by Truth API — → ledger

Sources