Have you heard about the proposed First National Bank of Trump? I get paid to know such things, but this kleptocratic scheme tiptoed past me earlier this month while I was distracted by our invasion of Venezuela; the phony criminal investigation of Jerome Powell; the Greenland invasion scare; ICE’s rising body count (eight dead so far in 2026); and the declining dollar. Among his many other accomplishments, President Donald Trump has altered our traditional experience of time.
The bank won’t actually be called the First National Bank of Trump, but it might as well. The Trump family crypto firm, World Liberty Financial, filed an application January 9 with the Office of the Comptroller of the Currency, or OCC, to charter a “trust bank” that will be called World Liberty Trust Company. A trust bank is a bank that doesn’t accept deposits or issue loans. The purpose of the bank would be to manage USD1, a stablecoin that World Liberty Financial created last March. USD1 is already the fifth-largest stablecoin in the world, with a market capitalization (Donald Trump, Jr., announced December 28) of $5 billion.
If you aren’t a cybercurrency person but nonetheless feel that “USD1” rings a bell, that’s probably because last May the United Arab Emirates purchased, from World Liberty Financial, $2 billion of USD1 to acquire a stake in Binance. Two weeks later the UAE persuaded the Trump administration to remove a Biden-era national-security restriction on the country’s importation of advanced AI chips. The Trump administration agreed to this this despite intelligence that UAE had previously shared technology with China that extended the range of Chinese missiles.
So far as we know, the UAE never enunciated any quid pro quo (“Here is the illegal bribe you asked for to send us some AI chips”). But members of the Witkoff family (Steve Witkoff is Trump’s special envoy to the Middle East, and also to Ukraine) were involved in both transactions, and so was Sheikh Tahnoon bin Zayed Al Nahyan, who manages the UAE’s sovereign wealth fund. Six months later, Trump gave Binance founder and convicted money launderer C.Z. Zhao a presidential pardon. When asked about this on 60 Minutes, Trump said “I don’t know who he is” and then contradicted himself by saying “He’s highly respected. He’s a very successful guy.”
I’ve stated previously (here and here) that the UAE’s USD1-for-AI-chips swap constitutes the biggest political bribery scandal since Teapot Dome, with the caveat that the Supreme Court has so thoroughly decriminalized political bribery in recent years that even if the Justice department still had a functional public integrity section (which it doesn’t), it isn’t obvious that a prosecutor would win a conviction. Albert Fall, eat your heart out.
But I digress.
World Liberty Financial was co-founded in December 2024 by Donald Trump; Witkoff; Trump’s sons (Don, Jr., Eric, and young Barron); and Witkoff’s sons (Zach and Andrew). Donald Trump and Steve Witkoff are now listed as “co-founder emeritus.” The company is frequently described as “Trump-backed,” but I’ve never encountered evidence that a Trump family member has put so much as a nickel into this venture. The Trumps do, however, extract money from it: according to Bloomberg, at least $890 million thus far. In addition, the Trump family owns World Liberty Financial tokens worth another $3.8 billion. The Trumps started out owning a 75 percent majority stake in World Liberty Financial, but that’s now down to 38 percent. We don’t know to whom the Trumps sold 37 percent of their stake, or how much they got paid for it, even though it seems we kinda should.
No Trump names appear on the application to the OCC to create World Liberty Trust Company. The application lists the proposed trust bank’s notional president as Zach Witkoff, who is also chairman and president of World Liberty Financial. The proposed bank’s notional board members include Zach; Zach’s uncle (Steve’s brother) Robert Witkoff; and Scott Alper, who’s president of the Witkoff Group, Steve Witkoff’s real estate firm. The bank would share office space with World Liberty Financial in Bar Harbor Islands, Florida.
Why does World Liberty Financial want a trust bank? Because the GENIUS Act passed last July subjected fintech to various options for regulatory oversight, of which the least burdensome is to receive a federal bank charter. According to a recent paper by Georgia State University assistant professor Todd Phillips, a federal bank charter shields the bank from state consumer protection laws and also provides potential access to a master account with the Federal Reserve that allows it to receive electronic funds. A federal bank charter also allows fintech companies like World Liberty Financial, rather than some third party, to be custodian of their own stablecoins, and to easily convert stablecoins to dollars and dollars to stablecoins. Many fintech firms have received bank charters already; the OCC seems to be handing them out like so much penny candy.
Unfortunately, Phillips points out, when a proposed trust bank is linked to the president of the United States, that president is liable to pressure the OCC to approve a charter. In a January 13 letter to Jonathan Gould, comptroller of the currency, Senator Elizabeth Warren, Democrat of Massachusetts, said that fear of precisely such a scenario prompted her to vote against the GENIUS Act. Warren also expressed annoyance that when she asked Gould about this possibility in July he declined to answer “hypothetical questions.” In addition, it seems to me, a president who’s already demonstrated an eagerness to tilt Fed policy to his political advantage probably wouldn’t balk at tilting it also to his commercial advantage (though not being familiar with the mechanics of the Fed’s master accounts, I can’t tell you exactly how).
“We have never seen financial conflicts or corruption of this magnitude,” Warren said in her January 13 letter. You can say that again. Constitutional emoluments-clause concerns about Trump’s Pennsylvania Avenue hotel during his first term now seem quaint. The nonprofit Citizens for Responsibility and Ethics in Washington, or CREW, sued Trump back then for violating the emoluments clauses. CREW prevailed in lower courts, but when it got to the Supreme Court the justices quietly set the matter aside until Trump left office so that they could declare it moot.
I asked Jordan Libowitz, CREW’s communications director, why CREW didn’t file a new lawsuit when Trump returned to the White House. He said that a legal challenge based on Trump’s crypto holdings would be more difficult because CREW would need to find a fintech company with standing to sue the president, and those don’t grow on trees. (Last time, DC had standing because it owned a rival hotel in the District.) “Trump is quite popular in the crypto space,” Libowitz observed. But yes, “the grift and corruption is on a scale way beyond what we saw in the first term.”
But surely some effort should be mounted to file an emoluments challenge again, if not by CREW (they’ve done their bit) then by someone else. Our president is totally out of control. A plaintiff with standing must be out there someplace. If you’re reading this and you’re a smart public interest lawyer, please give this half an hour of your time to think through.
