NCRC's Comment On World Liberty Trust Company National Trust Bank Charter Application

February 9, 2026

Jonathan V. Gould
Comptroller of the Currency
Office of the Comptroller of the Currency
400 7th St., SW
Washington, DC 20219

Via electronic mail: LicensingPublicComments@occ.treas.gov

RE: Public Comment Letter in Opposition to World Liberty Trust Company National Trust Bank Charter Application (2026-Charter-344521)

Dear Comptroller Gould,

The National Community Reinvestment Coalition (“NCRC”) strongly opposes the application by WLTC Holdings, LLC (WLTC Holdings) for a national trust bank charter under the name World Liberty Trust Company, National Association (World Liberty Trust).

NCRC is a coalition of more than 700 community-based organizations fighting for a just economy. For nearly 30 years, we have worked to create opportunities for people and communities to build and maintain wealth. NCRC members include community reinvestment organizations, community development corporations, local and state government agencies, faith-based institutions, fair housing and civil rights groups, minority and women-owned business associations, and housing counselors from across the nation. NCRC’s Innovation Council convenes fintech leaders to advance inclusive financial solutions. These partnerships create collaborative spaces where stakeholders share insights, develop strategies, and advance equitable access to financial services.

NCRC opposes WLTC’s application because of apparent conflicts of interest. WLTC Holdings seeks a national trust bank charter to issue and convert USD1 stablecoins, manage required reserves, and engage in custodial activities.^[1] It is affiliated with World Liberty Financial, which describes itself as a decentralized finance protocol and governance platform.^[2]Several individuals listed on World Liberty Financial’s website as its co-founders overlap with the proposed board of directors for World Liberty Trust but the extent of interconnectedness and the companies’ relationships to each other are unclear.^[3] Notably, the President and members of the President’s family and administration are included among the co-founders of World Liberty Financial and at least one administration official is on the proposed board of the World Liberty Trust.

Furthermore, NCRC opposes the grant of national trust bank charters to crypto and stablecoin companies because doing so is contrary to the purpose of the National Bank Act. It also will allow for regulatory arbitrage, result in the loss of community reinvestment, harm consumers and involve a lack of oversight and accountability, as well as pose risks to the safety and soundness of the financial system. Specifically, the grant of a national trust bank charter to WLTC Holdings would allow World Liberty Trust to offer custodial services, hold consumer funds, and manage settlements, without adequate safeguards in place.

Moreover, the bulk of the WLTC Holdings application references confidential attachments and thus, the full scope of the proposed trust’s operations and relationships to other related entities is unclear. This lack of information is particularly troubling given the potential for conflicts of interest and the involvement of the President, the President’s family, and members of the administration in the venture. These issues warrant additional inquiry and disclosure. Accordingly, the OCC must reject the WLTC Holdings application for a national trust bank charter, as outlined below.

1. The OCC should deny the WLTC Holdings application because of apparent conflicts of interest.

According to a recent article new report, “an entity affiliated with [President] Trump and his family members owns 38% of World Liberty [Financial]’s holding company.”[4] According to another article, 49% of World Liberty Financial is owned by investors tied to the United Arab Emirates as the result of a deal brokered by the UAE’s national security advisor.[5] Its company website lists President Trump and Steven Witkoff as co-founders emeritus. It also lists Donald Trump, Jr., Eric Trump, Barron Trump, Zack Witkoff and Alex Witkoff as co-founders.[6] Steven Witkoff currently serves as President Trump’s Special Envoy for to the Middle East and for Peace Missions. Thus, President Trump’s three sons and two of Steven Witkoff’s sons are co-founders of World Liberty Financial. The trust bank application lists Zack Witkoff as the proposed president, proposed director, and Chair of World Liberty Trust and his paternal uncle Robert Witkoff, as a proposed director.

We are concerned that the interconnectedness between the applicant and World Liberty Financial renders it impossible for the OCC to act impartially and creates the potential for the applicant to receive preferential treatment in the chartering process and beyond. If the OCC approves the national trust application, it “would put a Trump-linked business under the direct oversight of one of Trump’s regulators,”[7] namely, the OCC. The head of the OCC is removable at will by the president.[8] Although representatives of the World Liberty Financial have indicated that President Trump and his family lack control over the day-to-day operations of the trust bank applicant, [9] this scenario raises the potential for presidential abuse of power and undue influence over the chartering and supervisory process that could ultimately pose risks to “customers, competitors, and the wider financial system.”[10]

It is a general ethics principle that federal employees shall not use public office for private gain[11] but whether any of the parties are engaged in an actual conflict of interest under any law or rule is immaterial. Historically, under federal ethics rules, the appearance of a conflict of interest has been sufficient to raise conflict of interest concerns and prohibit the activities that underly the appearance of the conflict of interest.[12] Under those rules, the appearance of a conflict of interest can arise from the activities of family members – the test is whether a reasonable person with knowledge of the relevant facts would likely question the impartiality of the parties.[13] The granting of a national trust bank charter by the OCC, whose head is appointed and can be terminate at will by the President, to an entity that is closely affiliated with the President, his family, and other administration members, that would then be regulated by the OCC creates, at a minimum, the appearance of a financial conflict of interest. Because of the appearance of a possible conflict of interest, the OCC should deny the national trust application.

2. The OCC does not have authority to issue national trust bank charters to crypto and stablecoin companies such as WTLC Holdings.

The OCC charters national banks under the authority of the National Bank Act of 1864, as amended.[14] However, as a threshold matter, the OCC’s recent consideration and preliminary grants of limited purpose national trust charters for stablecoin issuers and other fintech firms exceeds the agency’s authority under the National Bank Act. Under the Act, the OCC’s grant of trust charters historically has been limited to institutions engaged in trust and fiduciary activities. The WLTC Holdings trust charter application does not delineate any planned fiduciary activities but states it will issue and redeem its USD1 stablecoins; maintain reserves on deposit with financial institutions; and engage in “custodial activities.”[15]

Rather than engage in the traditional responsibilities of a fiduciary,[16] the proposed trust bank would engage in core banking activities, including facilitating payments, as well as taking deposits. Despite the GENIUS Act’s clear prohibition on stablecoin interest or yield, WLTC Holdings would be creating deposit-like products through the rebranding of USD1 stablecoin returns as rewards or “points.”[17] As a national trust bank it would do so without regulatory safeguards, reshaping our financial system in ways that disproportionately burden vulnerable communities.

Although the WLTC Holdings trust bank charter application indicates it will not engage in extensions of credit, its affiliated company World Liberty Financial, recently announced it is launching a lending and borrowing product.[18] This, too, is a core banking activity and the application does not contain sufficient public information to assess what role, if any, a trust chartered bank would or could play in connection with World Liberty Financial’s lending platform. The launch of this program and its potential conflict with the purposes of a trust bank charter warrants further review.

The WLTC Holdings application clearly states that the trust bank will not have FDIC deposit insurance. Without access to such insurance or being subject to consolidated Federal Reserve supervision required of bank holding companies, granting firms like WLTC Holdings “limited-purpose trust charters would blur the statutory boundaries of what constitutes a ‘bank,’ undermine the credibility of the national charter, and heighten systemic risk by allowing them to operate under a lighter regulatory regime.”[19] It also creates potential systemic risks in the absence of corresponding safeguards, deposit insurance, or resolution mechanisms that protect depositors when traditional banks fail.

The OCC may deny an application if the applicant presents significant supervisory, compliance, or Community Reinvestment Act (CRA)^[20] concerns. In its review of applications, the OCC must consider whether its proposed activities are consistent with the purposes of the Federal Deposit Insurance Act, the National Bank Act, and the Home Owners’ Loan Act. As noted above, World Liberty Trust’s proposed activities are not consistent with the purposes of the National Bank Act and thus, the OCC does not have the authority to grant this entity a national trust bank charter.

Relatedly, the majority of the World Liberty Holdings application is contained in nonpublic attachments. The OCC is required to consider a number of factors and principles in reviewing national bank charter applications, including principles of safety and soundness,^[21] fair access to financial services,^[22] regulatory and legal compliance,^[23] and promotion of fair treatment.^[24] The regulations require that OCC assess whether the proposed institution:

Has organizers who are familiar with national banking laws and regulations or Federal savings association laws and regulations, respectively;^[25]
Has competent management, including a board of directors, with ability and experience relevant to the types of services to be provided;^[26]
Has capital that is sufficient to support the projected volume and type of business;^[27]
Can reasonably be expected to achieve and maintain profitability;^[28]
Will be operated in a safe and sound manner;^[29] and
Does not have a title that misrepresents the nature of the institution or the services it offers.^[30]

Unfortunately, as noted above, the public portions of the WLTC Holdings application do not contain sufficient information to adequately assess whether the OCC has sufficient information to determine whether WLTC Holdings meets these expectations and requirements.

3. Granting a national trust bank charter to WLTC Holdings would enable regulatory arbitrage that harms communities and consumers.

A national trust charter would provide WLTC Holdings with the reputational benefits, enhanced market credibility, and federal regulatory status of a banking institution while allowing it to avoid many of the fundamental obligations that justify such privileges. This arrangement would create dangerous imbalances in four areas: community investment responsibilities, consumer protection standards, regulatory oversight and accountability, and systemic risk management. Any form of national bank charter is a privilege, accompanied by obligations to communities and consumers. Approving the application of WLTC Holdings would create a two-tier system where digital asset firms receive comparable federal status without comparable public obligations, undermining the integrity of the entire chartering framework.

The US has a well-established legal and regulatory framework that governs banks and banking activities. This framework exists to ensure strong consumer protections, including transparency around fees and privacy; rigorous anti-money laundering (AML) and counter-terrorism financing requirements; fraud prevention and reporting obligations; deposit insurance to protect consumers’ funds; and the overall safety and soundness of the U.S. financial system. Issuing national trust bank charters to crypto and stablecoin companies, such as WLTC Holdings, enables regulatory arbitrage, weakens public trust, and exposes consumers and markets to unnecessary risk.

4. Lost Reinvestment to Communities and the Need for Community Development Obligations

National trust banks are not subject to Community Reinvestment Act (CRA) requirements, meaning WLTC Holdings – an entity that proposed to engage in some traditional banking services such as taking and holding deposits – would gain the prestige and benefits of a federal charter without any obligation to serve low- and moderate-income communities or meet local credit needs. Traditional banks must demonstrate how they reinvest deposits back into their communities—WLTC Holdings would face no such requirement.

Bank deposits fuel community development. A recent report indicated that stablecoins could divert around $500 billion of potential deposits from US banks by the end of 2028.[31] Issuance of a trust charter to WLTC Holdings would legitimize diverting potentially billions of dollars from community bank deposits into stablecoins held by an entity with no corresponding community reinvestment obligation. This diversion of capital away from entities with a community reinvestment obligation represents a fundamental departure from the principle that federally chartered institutions should serve public purposes, not merely private profit.

The CRA states that banks which benefit from federal deposit insurance have an obligation to meet the credit needs of entire communities, meaning that banks cannot solely serve the wealthiest customers. They must serve the needs of low- and moderate-income households as well. Stablecoin issuers should be held to CRA-like standards, as they will also rely on a supervisory regime that assures consumers that stablecoins are sound ways to store money.

Until stablecoin legislation requires stablecoin issuers to reinvest a portion of their proceeds into community development projects in underserved communities, no stablecoin issuer should receive any form of bank charter.

Traditional deposit insurance is a form of public subsidy to the banking industry in exchange for which banks accept obligations to serve the public interest. Granting trust bank charters to stablecoin firms will grant the patina of legitimacy to cryptocurrency issuers without the same obligations to serve the public.

The absence of community development obligations for stablecoin issuers means communities will lose billions of dollars of needed community and economic development projects and initiatives. In 2023 alone, banks originated over $127 billion in loans that meet the CRA’s definition of community development for LMI communities and households.[32] In addition, ensuring community development conditions are being met by nonbank or national trust bank issuers would also allow for a more level playing field between banks, especially community banks, and nonbank or national trust bank issuers.

5. Threat of Consumer Harm

As noted in several comment letters submitted by NCRC, granting a national trust bank charter to cryptocurrency and stablecoin companies threatens to harm consumers on multiple levels.

Consumers using stablecoins issued by a “national trust bank” would not have protections that federally insured deposits offer; however, the trust bank charter to WLTC Holdings will confer the appearance of regulatory legitimacy and safety,[33] which will likely mislead and confuse consumers. This perception gap increases public exposure to financial loss while allowing WLTC Holdings to benefit from the reputational privileges of the federal banking system without offering the core protections that actual banks provide.

A federal trust charter for WLTC Holdings would preempt state-level money transmitter licenses and many consumer protection laws that would currently apply to its activities in numerous jurisdictions. This federal preemption could weaken consumer protections that states have enacted specifically for digital asset activities. Trust banks are not FDIC-insured, but the “national bank” label could mislead consumers into expecting federal protection, creating moral hazard and exposing them to avoidable harm.

6. Lost Regulatory Oversight and Accountability: Stablecoin issuers should not be permitted to use a federal trust bank charter to avoid state-level consumer protections.

Traditional banks that maintain community reinvestment programs, robust compliance infrastructure, and comprehensive consumer protections would face a competitive disadvantage against WLTC Holdings because it would operate under a lighter trust charter while enjoying comparable market credibility. Non-depository fintech companies are subject to state-level registration and regulatory oversight requirements. Granting a national trust bank charter to stablecoin issuers enables regulatory arbitrage that would allow WLTC Holdings to gain federal banking status while avoiding the obligations and safeguards that justify such privileges, and while avoiding state-level supervision. The OCC should not permit WLTC Holdings to use a trust charter as a regulatory shortcut to avoid federal and state-level oversight while lacking the responsibilities and protections of insured banking institutions. The resulting competitive distortion could trigger a race to the bottom, incentivizing other institutions to seek similar arrangements.

7. Risks to Safety and Soundness

Despite the passage of the GENIUS Act, federal regulators have yet to finalize this law’s implementing regulations, which will be critical to establish clear rules for stablecoins, leaving critical issues of backing, redemption, and oversight in regulatory limbo. Even after the GENIUS Act and its implementing regulations all go into effect, which could take several years, legal scholar Art Wilmarth warns that “[b]y placing the federal government’s seal of approval on uninsured and weakly-regulated nonbank stablecoins, the GENIUS Act would greatly increase the likelihood that future runs on stablecoins would trigger systemic financial crises and require costly government bailouts.”[34]

Granting WLTC Holdings a trust bank charter before a comprehensive regulatory framework is in place would expose both consumers and the broader financial system to poorly understood risks. World Liberty Trust’s proposed banking operations would create an unprecedented moral hazard by extending the federal safety net to a company whose core business involves highly volatile digital assets. Stablecoin issuers operating through platforms like the open-issuance infrastructure of WLTC Holdings pursue profit-driven business models that are uniquely susceptible to destabilizing runs in the absence of rigorous reserve, redemption, and risk-management standards.[35] Historically, in the United States, bright lines have existed to separate banking from commerce. The separation of banking and commerce is critical to maintaining the safety and soundness of our financial system. The national trust bank charter is a problematic contradiction to that principle.

If WLTC Holdings receives a charter, regulators will have little insight into its corporate parent’s operations even though they have many interdependent relationships – compounding the systemic risks that WLTC Holdings and stablecoin operations already pose to the US economy.

8. The OCC must place a moratorium on all stablecoin company charter applications until laws and regulations can effectively address safety and soundness, fraud consumer protection, and undue foreign influence concerns.

The current regulatory framework governing cryptocurrency and stablecoins fails to prevent massive fraud and financial losses. It does not adequately address stablecoin liquidity standards, reserve requirements, or consumer protection, and these gaps have allowed criminal exploitation to flourish.

The digital asset ecosystem is plagued by fraud, hacking, and cybercrime, with billions of dollars in losses annually. US consumers are already losing billions of dollars a year to fraud, with stablecoins overtaking Bitcoin as the illicit currency of choice for criminals.

According to the FBI’s Internet Crime Complaint Center (IC3) 2024 Internet Crime Report, US consumer losses due to scams are increasing at a startling rate, rising from just under $4 billion in 2020, to over $16 billion in 2024.[36] Cryptocurrency has become the top way that complainants reported financial loss in fraud, accounting for $9.3 billion dollars in losses in 2024 alone.[37] As a group, those over the age of 60 suffered the most losses and submitted the most complaints referencing cryptocurrency.[38] Adding insult to injury, some stablecoin issuers do not cooperate with state law enforcement efforts to seize and return funds to crime victims and instead collect interest through investment on the underlying funds.[39]

While Bitcoin was the currency of choice for cybercriminals for years, this changed in 2022: a 2025 report shows a seismic shift to stablecoins that now account for 63% of all illicit crypto transactions.[40] In June of this year, the Financial Action Task Force (FATF), a leading global financial crime watchdog, recently called on countries to take stronger action to combat illicit finance in crypto assets, warning that gaps in regulation could have global repercussions.[41]

A related concern involves the applicant’s integration into the stablecoin and digital-asset payments ecosystem. WLTC Holdings is seeking a national trust charter to issue and convert stablecoins, provide digital asset services, and manage stablecoin reserves. These activities would place WLTC Holdings at the center of digital-asset infrastructure that has enabled widespread cryptocurrency-kiosk and wallet-based fraud—a rapidly growing consumer-protection crisis disproportionately harming seniors and vulnerable individuals.

While WLTC Holdings does not operate crypto kiosks or retail exchanges, it experienced at least one security breach this past fall. Prior to the launch of its platform, World Liberty Financial announced that several of its user wallets were compromised via phishing attacks or exposed seek phrases, requiring it to reallocate funds and issue new wallets.[42] It did not disclose the number of impacted wallets.[43] World Liberty Financial has also been in the news recently because Alt5 Sigma, a company that plays a role in the World Liberty Financial’s operations and has accumulated $1.5 billion in World Financial cryptocurrency, may have violated SEC rules.[44]

WLTC Holdings’ ownership structure and business activities raise serious questions about undue influence and regulatory risk. A watchdog group reported in September that World Liberty Financial may have sold WLFI tokens to sanctioned individuals or entities, prompting several US Senators to call for further investigation. [45] Individuals affiliated with the UAE hold a 49% ownership stake in WLFC. The scale and opacity of WLTC’s international investment heighten concerns that investors may leverage financial ties to seek preferential access or influence over US crypto and banking policy. [46]

Given the global scope of WLTC Holdings, its recent security lapse, the regulatory issues with at least one of its partners, and its foreign investments, the OCC should closely scrutinize whether WLTC Holdings possesses adequate anti-money-laundering, sanctions screening, and transaction monitoring controls to detect and respond to security breaches, and transactional patterns characteristic of kiosk-related scams and other crypto-enabled schemes.

Recent federal and state data underscore the scale of the threat posed by stablecoin and crypto-kiosk fraud. The Federal Trade Commission reported that consumers lost over $65 million to Bitcoin ATM scams in the first half of 2024, with a median individual loss of $10,000, and that older adults were several times more likely to be targeted.[47] FinCEN and multiple state attorneys general have documented that kiosks have been used to launder “millions” in criminal proceeds, prompting a wave of new state laws imposing transaction caps, disclosure mandates, refund rights, and operator registration requirements.

Finally, the OCC should also deny all stablecoin company charter applications until the Secretary of the Treasury has finalized rules to implement Section 5(A) of the GENIUS Act. That section of the Act provides that a permitted payment stablecoin issuer shall be treated as a financial institution for purposes of the Bank Secrecy Act, and as such, shall be subject to all federal laws applicable to a financial institution located in the United States relating to economic sanctions, prevention of money laundering, customer identification, and due diligence.

A recent report by the International Consortium of Investigative Journalists (ICIJ) found routine use of brand-name crypto exchanges by money launderers.[48] The ICIJ-led cross-border investigation with 37 media partners in 35 countries reveals how crypto and stablecoin companies provide the tools that criminals exploit to launder the proceeds of scams, theft, and other crimes — while those who’ve lost their savings or livelihoods are left with little hope of justice. The findings raise questions about whether exchanges are doing enough to stop illicit flows, either by freezing funds, closing accounts or carefully monitoring suspicious transactions.

Before the OCC considers granting a charter to any stablecoin issuer, the following rules and regulations implementing provisions of the GENIUS Act must be in place:

The Federal Reserve Board is authorized to issue regulations related to reserve requirements and liquidity standards for federally regulated stablecoin issuers.[49]
The Federal Deposit Insurance Corporation may issue rules to ensure that insured depository institutions issuing stablecoins comply with capital and risk management standards.[50]
The Department of the Treasury is authorized to issue rules on consumer protection, including public disclosures of reserve composition, redemption procedures and prohibited marketing practices.[51]
The Financial Crimes Enforcement Network is authorized to implement regulations under the Bank Secrecy Act to ensure anti-money laundering and sanctions compliance by stablecoin issuers.[52]
The Secretary of the Treasury is granted broad authority to issue rules and guidance necessary to carry out the act.[53]

Outstanding questions regarding conflict of interest, supervisory, compliance and CRA concerns must be addressed and the comment period for the charter application should be extended to allow for the release and review of additional information.

A key feature of the American democratic process is the opportunity for public engagement in the lawmaking process and in the American banking law this means the public’s right to participate by submitting comments on charter applications. A 30-day comment period for national trust applications is simply not sufficient for meaningful public engagement. The extensive nonpublic nature of the WLTC Holdings application means it lacks key information. Accordingly, we request that the OCC publicize the nonpublic portions of this and all stablecoin issuer charter applications (redacting any nonpublic personal information about the proposed entities’ officers or directors). And we request that the OCC extend the comment periods for this and all such applications to 90 days.

Moreover, this particular application raises a number of concerns, including potential conflicts of interest and risks of foreign influence. Before taking any action on this application, we request the OCC require the applicant to provide detailed information in public submissions addressing the following:

the relationships between World Liberty Financial, WLTC Holdings, and World Liberty Trust and the principals of each;
what steps, if any, World Liberty Holdings and its proposed national trust bank would take to avoid conflicts of interest, preferential dealing, and potential foreign influence;
whether World Liberty Financial’s lending program relates to the proposed national trust bank activities; and,
the extent to which World Liberty Trust would engage in direct consumer services.

For all the reasons outlined above, the NCRC strongly urges the OCC to stop issuing trust bank charters to crypto and stablecoin companies. We further urge the OCC to:

Consider the implications for communities if national trust banks serve as shells for large fintech or crypto platforms.
Establish guardrails to ensure national trust banks do not become vehicles primarily for regulatory arbitrage.
Conduct rigorous review of the applicant’s business operations and those of its affiliates.
Deny applications where there are appearances of conflicts of interest, preferential dealing, or potential undue foreign influence.
Address the safety and soundness and consumer fraud risks associated with the stablecoin trust charters.

Conclusion

The OCC must reject the application of WLTC Holdings for a national trust bank charter. Granting a national trust bank charter to WLTC Holdings raises significant conflict of interest concerns and would enable regulatory arbitrage, reduce investment into community development, risk significant harm to consumers and communities, and would create systemic risk. Finally, until the GENIUS Act is effective and its implementing regulations are finalized, granting a national trust bank charter to a stablecoin issuer will further fuel illicit finance and fraud that are already wreaking havoc on US consumers.

Thank you for considering this request. If you have any questions about this letter, please contact Jesse Van Tol, NCRC’s Chief Executive Officer, at 202-464-2709 or jvantol@ncrc.org.

Sincerely,

Jesse Van Tol
President and CEO
National Community Reinvestment Coalition (NCRC)

[1] Application to the Office of the Comptroller of the Currency to Organize World Liberty Trust Company, National Association (Jan. 5, 2026), https://occ.gov/topics/charters-and-licensing/digital-assets-licensing-applications/world-liberty-trust-company.pdf.

[2] World Liberty Financial Announces that WLTC Holdings LLC Has Submitted an Application for a National Trust Bank Charter to Issue and Custody USD1 Stablecoins, Bus. Wire (Jan. 7, 2026), https://www.businesswire.com.

[3] World Liberty Financial, We’re the Bridge Between Legacy and What’s Next, https://www.worldlibertyfinancial.com (last visited Feb. 4, 2026).

[4] Declan Harty, Donald Trump Promised to Make the U.S. the World’s Crypto Capital. His Businesses Are Seizing on It, Politico (Jan. 29, 2026), https://www.politico.com/news/2026/01/29/donald-trump-crypto-currency-00753616.

[5] Matt Viser, Trump Family Crypto Firm Sold Major Stake to UAE Investment Firm, Wash. Post (Feb. 1, 2026), https://wapo.st/4bsjrwV.

[6] World Liberty Financial, Team, Vision & Mission, https://www.worldlibertyfinancial.com (last visited Feb. 4, 2026).

[7] Harty, supra note 4.

[8] 12 U.S.C. § 2 (“The Comptroller of the Currency shall be appointed by the President, by and with the advice and consent of the Senate, and shall hold his office for a term of five years unless sooner removed by the President, upon reasons to be communicated by him to the Senate.”).

[9] Harty, supra note 4.

[10] Todd Phillips, Presidentially‑Connected Firms and the Importance of Regulatory Independence, Chi.-Kent L. Rev. (forthcoming 2026), https://papers.ssrn.com/sol3/papers.cfm?abstract_id=5387414; see also Leo Schwartz, World Liberty Financial’s Bid for a U.S. Bank Charter Raises New Questions About Trump’s Crypto Conflicts, Fortune (Jan. 12, 2026), https://finance.yahoo.com/news/world-liberty-financial-bid-u-120846017.html.

[11] 12 C.F.R. § 2635.101(a)(7).

[12] Office of the Comptroller of the Currency, Ethics Rules: A Plain English Guide, https://careers.occ.gov/careers/apply/occ-ethics-rules-a-plain-english-guide.html (last visited Feb. 4, 2026).

[13] 12 CFR § 2635.502.

[14] National Bank Act of 1864, 12 U.S.C. §§ 1 et seq.

[15] World Liberty Trust Charter Application, supra note 1. The extent to which the custodial activities would be for consumers as opposed to institutional investors is unclear.

[16] According to 12 CFR § 9.2(e), they are: Trustee, executor, administrator, registrar of stocks and bonds, transfer agent, guardian, assignee, receiver, or custodian under a uniform gifts to minors act; investment adviser, if the bank receives a fee for its investment advice; any capacity in which the bank possesses investment discretion on behalf of another.

[17] James Hunt, Trump‑Affiliated World Liberty Financial Plans Loyalty Points Program for USD1 Stablecoin Users, The Block (Aug. 7, 2025), https://www.theblock.co.; see also Pooja Rajkumari, Trump-backed Stablecoin Quietly Overtakes PayPal Amid Binance Boost, The Street Roundtable (Jan. 23, 2026), https://www.thestreet.com/crypto/trading/trump-backed-stablecoin-quietly-overtakes-paypal-amid-binance-boost.

[18] Kyle Baird, Trump‑Backed World Liberty Moves into Crypto Lending as USD1 Climbs Stablecoin Ranks, The Block (2025), https://www.theblock.co/post/385131.

[19] Austin Anton, BPI Urges OCC to Preserve the Integrity of National Trust Charters, Bank Policy Inst. (Oct. 31, 2025), https://bpi.com/bpi-urges-occ-to-preserve-the-integrity-of-national-trust-charters/.

^[20] Id. at 4.

^[21] 12 C.F.R. § 5.20(f)(1)(i).

^[22] 12 C.F.R. § 5.20(f)(1)(ii).

^[23] Id.

^[24] Id.

^[25] 12 C.F.R. § 5.20(f)(2)(i)(A).

^[26] 12 C.F.R. § 5.20(f)(2)(i)(B).

^[27] 12 C.F.R. § 5.20(f)(2)(i)(C).

^[28] 12 C.F.R. § 5.20(f)(2)(i)(D).

^[29] 12 C.F.R. § 5.20(f)(2)(i)(E).

^[30] 12 C.F.R. § 5.20(f)(2)(i)(F).

[31] Hannah Long, U.S. Banks May Lose $500 Billion to Stablecoins by 2028, Standard Chartered Warns, Reuters (Jan. 27, 2026), https://www.reuters.com.

[33] For example, Tether recently announced that its stablecoin, USAT “is now available. . . to operate within the U.S.’s dedicated federal regime” and described it as “a U.S.-regulated dollar-backed stablecoin.” Tether Announces the Launch of USAT, the Federally Regulated, Dollar‑Backed Stablecoin, Tether (Jan. 27, 2026), https://tether.io/news/tether-announces-the-launch-of-usat-the-federally-regulated-dollar-backed-stablecoin-made-in-america/.

[34] Arthur E. Wilmarth, Jr., Congress Must Reject the GENIUS Act and Remove the Dangers Posed by Nonbank Stablecoins, Open Banker (2025), https://ourfinancialsecurity.org/wp-content/uploads/2025/07/AFR-Factsheet.GENIUS-Acts-Flaws-and-Failures.pdf.

[35] Financial Stability Oversight Council, 2024 Annual Report (Washington, DC: U.S. Department of the Treasury,

2024) at 8, https://home.treasury.gov/system/files/261/FSOC2024AnnualReport.pdf.

[36] Federal Bureau of Investigation, 2024 Internet Crime Report (Washington, DC: Internet Crime Complaint Center, 2025) at 7, https://www.ic3.gov/AnnualReport/Reports/2024_IC3Report.pdf.

[37] Id. at 3.

[38] Id. at 35.

[39] Allison Morrow, Stablecoin Law Allows Crypto Firms to Profit from Fraud, Prosecutors Say, CNN (Feb 2, 2026), https://www.cnn.com/2026/02/02/business/stablecoin-genius-act-crypto.

[40] Chainalysis, 2025 Crypto Crime Report (Jan. 15, 2025), https://www.chainalysis.com/blog/2025-crypto-crime-report-introduction/.

[41] Global Financial Crime Watchdog Calls for Action on Crypto Risks, Reuters (June 25, 2025), https://www.reuters.com.

[42] World Liberty Financial Burns, Reallocates $22.1M in WLFI Due to Pre‑Launch Wallet Breach, Crypto.News (Nov. 19, 2025), https://crypto.news/world-liberty-financial-wlfi-wallet-breach-2025/.

[43] Was Trump Crypto Project WLFI Just Hit with a Security Breach?, Yahoo! Fin. (Nov. 20, 2025), https://finance.yahoo.com/news/trump-crypto-project-wlfi-just-104712917.html.

[44] Zach Everson, Trump Crypto Partner Alt5 Sigma May Have Violated SEC Rules, Forbes (Dec. 1, 2025), https://www.forbes.com. /.

[45] Rashmi Ramesh, World Liberty Financial Scrambles to Secure User Funds, Bank Info Security (Nov. 27, 2025), https://www. bankinfosecurity.com/cryptohack-roundup-wlf-scrambles-to-secure-user-funds-a-30157.

[46] Eric Lipton et al., Secret Deals, Foreign Investments, Presidential Policy Changes: The Rise of Trump’s Crypto Firm, N.Y. Times (Apr. 29, 2025),https://www.nytimes.com/2025/04/29/us/politics/trump-crypto-world-liberty-financial.html.

[47] Federal Trade Commission, “New FTC Data Shows Massive Increase in Losses to Bitcoin ATM Scams,” press release, September 3, 2024, https://www.ftc.gov/news-events/news/press-releases/2024/09/new-ftc-data-shows-massive-increase-losses-bitcoin-atm-scams.

[48] International Consortium of Investigative Journalists. (n.d.). About Coin Laundry investigation: Cryptocurrency. ICIJ. https://www.icij.org/investigations/coin-laundry/about-coin-laundry-investigation-cryptocurrency/ (last visited Feb. 4, 2026).

[49] GENIUS Act, S. 1582, 119th Cong. § 4(e)(2).

[50] Id. § 4(e)(3).

[51] Id. § 6(a)–(c).

[52] Id. § 7(b).

[53] Id. § 13(a).