Written by: Leonardo Nicoletti, Anthony Cormier, David Kocieniewski
Translated by: Luffy, Foresight News
Among the large holders of the Trump meme coin, more than half come from foreign trading platforms that claim to prohibit U.S. users, indicating that many buyers are based outside the U.S.
Trump is a cryptocurrency that President Trump began promoting just days before his inauguration. Following an unprecedented promotional campaign, sales of the Trump token surged over the past two weeks: More than 200 of the largest token holders will be invited to a dinner on May 22 at Trump’s Virginia golf club, while the top 25 holders will be eligible to attend an exclusive reception before the dinner and a 'VIP' tour described on the Trump token website.
Currently, Bloomberg News's analysis shows that among the top 25 registered holders on the website leaderboard, only 6 of them are using foreign trading platforms that claim not to accept U.S. residents. Among the top 220 holders on the leaderboard, at least 56% are using similar offshore trading platforms. The widespread presence of these potential foreign buyers echoes the ethical concerns raised by Congressional Democrats regarding promoting tokens with promises of contact with the president. This also raises questions about how the participants in the promotional dinner will be scrutinized, as their public identities can only be linked to usernames consisting of a few letters.
Most of the large holders of the Trump token may be based outside of the United States
The current value of tokens held by the 220 cryptocurrency wallets registered on the TRUMP leaderboard (by the possible location of wallet holders). Among the top 220 wallets, 76% of the token value may belong to foreign owners, as these wallets are using trading platforms not available to U.S. residents.
Data Source: Bloomberg's analysis of SolScan data.
(Note: Data as of May 5 at 10 AM Eastern Time. Usernames are those listed on the TRUMP token website, set by wallet holders when registering for the dinner promotion. One wallet that remains in the top 25 on the leaderboard is not listed here as it nearly sold off all its tokens on May 3.)
In the website's terms, the organizers state that participants must undergo a background check. The website states: 'We will also review your wallet for KYC and compliance purposes. You will dine with the President of the United States!' However, the website does not specify how such reviews will be conducted.
The promoters of the TRUMP token did not respond to requests for comment, nor did White House officials.
To appear on the dinner leaderboard, individuals who purchased TRUMP coins must register on the website, which claims it will rank them based on the number of tokens held and the duration of holding. Many large holders have not registered. However, another analysis by Bloomberg of all the largest buyers (regardless of whether they are on the leaderboard) shows that more than half of this broader group of buyers also comes from foreign trading platforms.
It is possible that some U.S. buyers found ways to circumvent the ban by using foreign trading platforms, such as using virtual private networks (VPNs) to hide their U.S. IP addresses. Most trading platforms state that they have measures in place, such as collecting users' personal information, to try to prevent such circumvention. The three foreign trading platforms most commonly used by large holders of the TRUMP token to fund accounts or purchase TRUMP coins are Binance, Bybit, and OKEx, all of which have restrictions on U.S. users. Bloomberg's analysis found that before OKEx launched its trading platform in the U.S. on April 15, there were 6 holders on the TRUMP token leaderboard who made purchases on that platform. An OKEx spokesperson stated that prior to this, the company did not allow U.S. residents to make purchases. Representatives from Binance and Bybit did not respond to requests for comment.
Two of these three trading platforms had previously violated U.S. laws. In November 2023, Binance pleaded guilty to violating federal anti-money laundering and sanctions laws due to internal controls and paid over $4 billion to the U.S. OKEx admitted to violating anti-money laundering regulations in February and paid over $420 million.
Cryptocurrency projects related to Trump have attracted a significant amount of foreign investors before.
Hong Kong cryptocurrency entrepreneur Justin Sun became an advisor to another cryptocurrency project promoted by the Trump family, World Liberty Financial (WLF), after announcing the purchase of tokens worth tens of millions of dollars. Sun stated at the time that he did not expect to receive any benefits from Trump for this investment. According to Bloomberg's analysis of cryptocurrency wallet transactions, Sun may also be a large holder of the TRUMP token.
On May 8, 2020, Justin Sun, founder of the blockchain platform Tron, was in Hong Kong
Source: Bloomberg
World Liberty is promoting a stablecoin. One of the company's co-founders, Zach Witkoff, son of Trump's Middle East envoy, announced on Thursday at a meeting that this stablecoin will be used to facilitate transactions between Binance and an investment company founded by the Abu Dhabi government. Executives from World Liberty did not respond to requests for comment.
Tony Carrk, executive director of the non-profit organization Accountable.US, stated: 'Congress should demand the president disclose those who are secretly contributing to him to assess whether the public interest is being harmed.' The organization has set up an 'Accountability War Room' online. Accountable.US found that among the top 50 holders of World Liberty tokens, at least 14 also used cryptocurrency services inaccessible to Americans. Bloomberg's analysis discovered another 8 such wallets. World Liberty disclosed in November that its initial $300 million issuance was primarily sold overseas.
Many large holders of the WLF token are located abroad
Holding status of the 50 wallets with the most WLF tokens (by the possible location of wallet holders)
Data Source: Accountable.US, Bloomberg's analysis of Etherscan data
Note: Data as of April 30 at 6:45 PM Eastern Time
Trump, who once called Bitcoin a 'scam against the dollar', is now deeply involved in the cryptocurrency space while his administration has begun to dismantle the regulatory and enforcement teams that were originally responsible for overseeing these digital assets. For example, shortly after he took office, staff at the SEC responsible for investigating cryptocurrencies were reassigned, and many of their cases were shelved. In April, the Justice Department disbanded its cryptocurrency task force.
Last month, Democratic Senators Adam Schiff and Elizabeth Warren called on the U.S. government's ethics office to investigate the Trump token dinner promotion. They stated that the May 22 event poses 'serious risks that President Trump and other officials may engage in corrupt behavior by selling opportunities for personal or entity contact with the president, while allowing the president and his family to profit personally.'
The Trump family benefits from the rise in TRUMP token prices, as a company they control holds a large amount of these tokens. Although the Trump family cannot sell any tokens for a period of time according to the token issuance terms, any fluctuations in price will alter their wealth status on paper. The announcement of the dinner on April 23 caused the token price to rise from around $9 to about $14, leading to 436 new transactions exceeding $100,000 in the following five days, with the largest transactions involving accounts interacting with platforms not operating in the U.S.
There was a surge of foreign purchases after the dinner announcement
Purchases of the TRUMP token exceeding $100,000 in April
Data Source: Dune; Bloomberg's analysis of SolScan data
Note: Data as of May 1
To qualify for dinner with Trump, token holders must register a 'self-custodied' wallet, one that is fully controlled by the holder and not by a third-party trading platform.
Bloomberg analyzed the trading activity of the top 220 wallets on the dinner leaderboard as of May 5 to determine whether their holders may be based abroad. Another separate analysis studied all self-custodied wallets that held enough Trump tokens to qualify for the top 220 as of April 30. Many of the largest holding wallets are not listed on the dinner leaderboard, indicating they may not have registered or that their time-weighted holding amounts may significantly differ from current holdings. Some may be strategically waiting to register.
While it is difficult to identify the individuals behind these accounts, there are public clues about some of them. In recent days, entities on the leaderboard have been swapping places, with at least one entity bragging about it online. A wallet named 'MeCo' belongs to an entity called 'Memecore', which claims to be a 'multi-chain cross-staking mainnet compatible with the Ethereum Virtual Machine (EVM), protected by a meme proof mechanism.'
The company stated on the X platform: 'We not only want to top the TRUMP leaderboard but also to conquer the entire meme coin space.' Memecore is requesting users to send them their TRUMP tokens to improve their ranking. The company stated that the tokens will be returned to users afterward, along with bonuses.
Cherry Hsu, Chief Business Development Officer of Memecore, stated in a statement on Telegram: 'Currently, the meme coin space is considered stagnant, and we want to challenge that notion. By participating in this event, we want to show that the meme coin space is rising again.'
According to Bloomberg's analysis of blockchain data, the leader Memecore is chasing on the leaderboard chose the username 'Sun' and used a wallet associated with HTX, which is linked to Justin Sun. Sun himself has publicly acknowledged purchasing World Liberty Financial tokens, but so far he has not clarified whether he is the owner of the top wallet on the leaderboard. He did not respond to requests for comment.
A wallet labeled 'Sun' began accumulating tokens worth a total of $17.9 million when the Trump token was initially launched in January. Since the announcement of the Trump dinner promotion, it has purchased an additional $4.5 million worth of tokens.
In 2023, the SEC sued Justin Sun, accusing him of collaborating with companies he owns and controls to orchestrate the issuance and sale of unregistered securities. Sun's lawyer denied the allegations and stated that the agency's claims are 'too far-fetched and should be dismissed.' In February, after Sun spent at least $75 million purchasing World Liberty Financial tokens, the SEC paused its litigation against him, stating that considering potential solutions is in the best interest of both parties.
