A Trump-Linked Crypto Firm Just Won Approval for a National Bank, and the Regulator’s Decision Listed Every Conflict of Interest But Approved It Anyway
An image of Donald Trump at a Trump-Vance podium with a crowd in the background_ Image by Phil Mistry via Shutterstock_
The institution the Office of the Comptroller of the Currency (OCC) conditionally approved on Aug. 14 cannot take deposits and cannot make a loan. It has no employees, no capital, and no opening date. If it fails to raise $20 million within 12 months, or fails to open within 18 months, the approval expires on its own terms. None of that is the interesting part.
The interesting part is the document, Corporate Decision #1385, filed under OCC control number 2026-Charter-344521, grants preliminary conditional approval to World Liberty Trust Company, National Association, of Bay Harbor Islands, Florida, a limited-purpose national trust bank connected to World Liberty Financial, the crypto venture whose co-founders include Eric Trump, Donald Trump Jr., and Barron Trump. And before it grants anything, the letter sets out, in the regulator’s own words, every objection that was filed against it.
Start with what the bank would do. The decision describes its proposed activities as “dollar-backed stablecoin issuance and redemption and reserve maintenance in a nonfiduciary capacity; digital asset custody services as a fiduciary; and conversion services for custody customers.” In plain terms, it plans to issue (USD1USD), World Liberty Financial’s dollar-pegged stablecoin, to institutional clients nationwide, “assuming this role from BitGo Bank & Trust, National Association (BitGo), the current exclusive issuer and custodian for USD1.”
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A trust charter is not a deposit-taking bank charter. The letter is explicit that under the GENIUS Act, “stablecoins are not deposits under the FDI Act,” that payment stablecoins “shall not be subject to deposit insurance by the FDIC,” and that it is unlawful to represent otherwise. Barchart has covered what a trust charter actually signals to Wall Street when Circle (CRCL) obtained one. And the approval is preliminary; final authorization to commence business “will not be granted until all preopening requirements are met.”
A Closer Look at the Concerns
Then comes the section nobody has quoted. “The OCC received seven comments on the application from four commenters,” the decision states. Four of them, it records, “expressed concerns about potential conflicts of interest involving the Bank, President Donald J. Trump and his family, Alexander and Zachary Witkoff, and United Arab Emirati investors in World Liberty Financial, Inc.”
Three commenters, the letter continues, “suggested that the Bank could receive preferential treatment by the OCC because the Comptroller is a presidential appointee.” One went further, suggesting the Comptroller “could abstain from enforcing laws and regulations against the Bank or over enforce laws and regulations against rivals of the Bank.” Another argued that certain purchases of (WLFIUSD) tokens “could potentially violate the Emoluments Clause.” Several asked the OCC to hold the application until the Committee on Foreign Investment in the United States had reviewed World Liberty Financial’s foreign investors.
The OCC’s Response
The OCC’s answer is one sentence, and it is jurisdictional rather than factual. Comments “related to potential conflicts of interest or violations of law or of the Emoluments Clause related to certain purchases of WLFI tokens are outside the scope of the OCC’s review,” the decision says. On the foreign-investor question, it discloses a step it did take: While those investors “were not considered principal shareholders of the Bank,” the OCC says it received passivity commitments. It also rejected the argument that the comment period was too short, noting that the commenters “were nonetheless able to timely provide voluminous comments on the application.”
The decision states no ownership percentage for anyone. Reporting on the application has put an affiliate of President Trump and certain family members at a 38% interest in World Liberty Financial, a figure drawn from the company’s own disclosure language, not the OCC’s file, and one describing an affiliated entity’s stake in the crypto venture rather than a personal holding in the proposed bank. Barchart has covered the scale of the president’s crypto income in 2025.
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The conditions attached are more demanding than the coverage suggested. The bank “must maintain a minimum of $20 million in tier 1 capital of which the greater of at least 50 percent of its tier 1 capital or $10 million must be held in Eligible Liquid Assets,” and must reassess capital and liquidity quarterly. An auditor must be engaged and “will be verified during the preopening examination.” A further condition requires the bank to conform its stablecoin activities to the GENIUS Act, and if they do not comply, “the condition requires the Bank to cease or divest of such activities.”
Neither World Liberty Financial nor the White House is quoted in the decision document; the scope determination is the only response to those comments that appears on that record. What exists today is a 14-page letter, a set of conditions, a clock, and a bank that has not opened. Whether it does open is a question the next OCC licensing bulletin answers, not this one.
On the date of publication, Caleb Naysmith did not have (either directly or indirectly) positions in any of the securities mentioned in this article. All information and data in this article is solely for informational purposes. For more information please view the Barchart Disclosure Policy here.
