On Friday afternoon the federal government handed a bank charter to World Liberty Financial - the crypto company 38% owned by an entity tied to Donald Trump and his family. Trump personally owns 70% of said entity.
The agency that did it is the Office of the Comptroller of the Currency. It sits inside the Treasury Department but there’s no bipartisan board, no commission, no one who has to agree with anyone else. There is one Comptroller, and they are appointed by the President himself - that’s it. And conveniently enough, per the Senate Banking Committee, Trump had already asserted control over the OCC by executive order before any of this banking bullshit began.
Senator Elizabeth Warren, ranking Democrat on that committee (and absolute investigative menace whom we must protect at all costs), did not stutter when she said:
Every outlet ran that quote, but it feels like none of them actually read through to the back of the letter, because it’s far more fucked up than anyone is saying.
The pinky swear
Once you scroll past the conditions, footnotes, and signature on the approval letter - you hit three enclosures called passivity commitments.
A passivity commitment is what you sign when a regulator asks whether or not you plan to control a bank you own a piece of and you’d prefer the answer be no. It is a promise. A written one. On purpose.
The first one is labeled “Passivity Commitments by DT Marks SC LLC.”
DT Marks is what the Trump Organization slaps on the front of a shit-ton of its entities. DT Marks DEFI LLC holds the family’s stake in World Liberty Financial. DT Marks SC LLC is a shareholder in the holding company that will own this bank.
So the family owns part of the bank. And what the United States government accepted as protection against them using it - is a piece of paper where they agree to be good. Something they have spent most of their documented time failing to prove they are capable of.
What did they agree to?
• DT Marks won’t do anything that turns the bank into its own subsidiary.
• They won’t install a representative as an officer, agent or employee.
• They won’t run a rival slate of directors.
• They won’t seek or use material non-public information. (Private information about a company that could impact its stock price.)
• And if they ever own 10% or more, everything above 9.9% has to be handed to management and voted in whatever proportion the other shareholders vote, so it can’t be used as leverage.
If they break any of those promises, the document says DT Marks “will have intentionally exercised a controlling interest in the Bank” and can face administrative action. (Donald Trump is the administration)
Who signed that written promise?
Eric F. Trump, President.
The President’s son signed a federal document swearing the family won’t touch a national bank the family owns. A federal agency read that, accepted it, stamped it, and stapled it to the back of an approval. Because regulatory dignity and decency have died.
But it gets worse. The other two signatures?
The second belongs to StringZ Holding RSC (DE) LLC, signed by a man named Hamad Khlfan Ali Matar Alshamsi. He is not American. That name is a story in and of itself - and man is that one fucking coming - but it is far too big to bury in a paragraph here, so bear with me.
The third is AMGUS, LLC, signed by Zachary Folkman, Managing Member. Folkman co-founded World Liberty Financial and signed its original securities paperwork with the SEC back in 2024.
Three shareholders - a Trump entity, a founder’s entity, and a foreign one. All three swore they won’t run the bank. The government took all three of them at their word and considered it oversight. Because apparently, the American government has collectively lost their minds.
Decision #1384 and Decision #1385
The approval for all of this is Corporate Decision #1385, out of the OCC’s Chartering, Organization and Structure division - signed by Senior Deputy Comptroller Stephen A. Lybarger.
Corporate Decision #1384 is dated ten days earlier. It’s the same division with the same man’s signature - but ten days prior to approving the Trump-affiliated bank, it denied a charter to the Dutch fintech “bunq.”
Here’s what bunq was told, in the agency’s own words. The application “does not demonstrate that bunq USB has capital that is sufficient to support the projected volume and type of business.” The organizers “did not provide sufficient support for their claims regarding the initial capitalization.” And the OCC “concluded unfavorably regarding the general character and fitness of the management,” based on “transparency concerns regarding inconsistencies in what bunq USB’s management was communicating to the OCC.”
Two weeks before that, the same office denied Wise, which had applied for the exact same kind of charter World Liberty just walked away with. Lybarger’s letter cited significant supervisory and compliance concerns, state anti-money-laundering actions, and organizers who hadn’t shown sufficient familiarity with federal banking law.
(According to Reuters, Capital One closed Trump’s bank accounts “after a review by anti-money laundering experts.” The bank has never accused the Trump Organization of illegal money laundering.)
Bunq got refused, in part, over capital. World Liberty got approved with a $20 million floor propping up a stablecoin carrying roughly $4 billion.
Michele Alt of Klaros Group told American Banker that observers would be comparing this approval against those denials on capitalization, management and regulatory history - which was so polite of her. I am not polite. An agency that just spent a summer telling foreign fintechs their management wasn’t fit to run a bank, handed one to the family of the man who appoints its fucking boss.
What the agency decided wasn’t its problem
The public filed comments prior to this decision being made - comments that should have been taken into consideration. Some raised fantastic points regarding the Emoluments Clause of the Constitution. One asked the OCC to wait until certain non-US investors divested from World Liberty Financial.
The letter’s answer to both of those points - is that those comments fall outside the scope of its review, because neither World Liberty Financial nor any foreign investors in it are a party to the application.
On foreign ownership, the letter says CFIUS review, the process that screens foreign investment for national security risk, is outside the scope of its review.
Foreign money is apparently not their department. Nor is the Constitution.
Money laundering, missing reserve requirements, absent consumer protections, and the whole principle that banking and commerce stay separate - were all logged in one section of the letter and then dropped off at someone else’s house like it wasn’t their problem.
The agency then defended itself in writing by saying the Comptroller and staff acted consistently with their statutory duties and ethical obligations - and that approvals like this get made under authority the Comptroller delegates to career staff. It’s giving blame-game, which is only played when someone does something stupid.
Having written all that down, the OCC then declined to comment on its own decision - which is bitch-boy behavior.
Spare us the partisan bullshit
Bank trade groups opposed this too. So did Americans for Financial Reform Education Fund (AFR), a consumer watchdog, which said Friday evening that the OCC “exceeded its statutory authority and longstanding judicial precedent to unlawfully grant” the charter.
A trust bank’s entire job is holding other people’s assets and being legally bound to put those people first. AFR’s position is that this company can’t be handed that job given its relationships with, in their words:
“convicted money-launderers (some subsequently pardoned by Trump) and foreign investors, including a 49 percent stake by a United Arab Emirates sovereign wealth fund that also has two board seats on the WLF parent company.”
And I genuinely wish they were exaggerating for effect - but I’ve literally already written about this. Binance founder Changpeng Zhao pleaded guilty in 2023 to failing to maintain an anti-money-laundering program. His company paid $4.3 billion, he did four months in prison, and then Trump pardoned his ass on October 23, 2025 - just months after an Abu Dhabi state fund used World Liberty’s stablecoin to buy $2 billion worth of Binance.
Fun fact: Justin Sun bought $30 million worth of World Liberty tokens in November 2024. Three months later the SEC asked a judge to pause its fraud case against him and the judge said yes.
None of that was an ambiguous talking point. A consumer watchdog is accusing a federal agency of acting illegally - and they listed examples.
What Zach Witkoff said
Zach Witkoff chairs the bank, because of course he does. He’s the son of Steve Witkoff, the sitting US Special Envoy to the Middle East. His statement read:
“We welcome continuous scrutiny from Federal regulators for many years to come.”
The regulators in question answer to a Comptroller the President appointed, at an agency the President asserted control over by executive order, examining a bank the President’s family owns part of, on a charter the President’s son signed paperwork for.
This is the confidence of a rich frat boy wearing a “do you realize who my dad is?” hat. The hat is red.
So
No one has been charged with anything and I’m not accusing anyone of a crime. Because allegedly and shit. Also, crime seems somewhat legal at this point, depending on your net-worth and relationship to those in charge. But hey - what the fuck do I know?
Circle, Ripple, Paxos and BitGo have all been approved by this same agency, which has taken in roughly 40 applications since 2025. A crypto company getting one is not the scandal here - though, honestly, it should be, but unfortunately we’re far past DEFCON crypto.
The scandal now, is that the President’s family owns a piece of a federally chartered bank and the only thing standing between them and it - is a piece of paper signed by a guy who was barred from being an officer or director of any New York corporation for 2 years, an order the appeals court later stayed. Eric. We’re talking about Eric Trump.
Ten days before he signed that, the same official refused another bank because he wasn’t satisfied it had enough money and wasn’t satisfied that its management was fit to run one. Then he did this shit, on a Friday afternoon in August, when nobody was supposed to be looking because it was a fucking Friday afternoon.
Financial disclosures released in June show Trump took around $550 million from World Liberty token sales last year and more than $1.4 billion in crypto earnings overall.
And when the public asked about foreign money and the Constitution, the answer was that those questions fall outside the scope of their review.
They’re not outside of the scope. They are quite literally the only thing anyone should be reviewing.
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