Source: Leonardo Nicoletti, Anthony Cormier, David Kocieniewski
Compiled by: Luffy, Foresight News
More than half of the major holders of Trump Meme Coin are from foreign trading platforms that claim to ban American users, indicating that many buyers are from outside the United States.
Trump is a cryptocurrency that President Donald Trump began promoting days before Inauguration Day. Sales of Trump Tokens have surged in the past two weeks following an unprecedented promotion: More than 200 of the largest token holders will be invited to a May 22 dinner at Trump’s Virginia golf club, while the top 25 holders will be eligible for an exclusive pre-dinner reception and what the Trump Token website describes as a “VIP” tour.
Now, a Bloomberg News analysis shows that all but six of the top 25 holders registered on the site’s leaderboard used foreign exchanges that claimed to not accept U.S. residents. And at least 56% of the top 220 holders on the list used similar offshore exchanges. The prevalence of these potential foreign buyers echoes congressional Democrats’ concerns about the ethics of promoting tokens with the promise of access to the president. It also raises questions about how the promotional dinner attendees, whose public identities can be linked only to a username consisting of a few letters, will be vetted.
Most of the Trump Token holders may be outside the United States
The value of tokens currently held by the 220 cryptocurrency wallets registered on the TRUMP leaderboard (by where the wallet holders are likely to be located). 76% of the value of tokens held in the top 220 wallets may belong to foreign owners because these wallets use trading platforms that are not available to US residents. Data source: Bloomberg analysis of SolScan data. (Note: Data as of 10 am EST on May 5. Usernames are listed on the TRUMP token website and are set by wallet holders when they register for the dinner promotion. One wallet that is still in the top 25 of the leaderboard website is not listed here because it sold almost all of its tokens on May 3)
In the fine print on the website, organizers say attendees must pass a background check. “We will also review your wallet for KYC and compliance purposes,” the website reads. “You will be having dinner with the President of the United States!” But the website does not explain how such a review will be conducted.
Promoters of the TRUMP token did not respond to requests for comment, nor did White House officials.
In order to appear on the dinner leaderboard, people who bought TRUMP coins must register on its website, which says it will rank them based on the number of tokens they hold and how long they have been held. Many large holders have not yet registered. But another analysis by Bloomberg of all the largest buyers (whether on the leaderboard or not) shows that more than half of this broader group of buyers are also from foreign trading platforms.
It’s possible that some U.S. buyers have found ways to get around the ban by using foreign exchanges, such as using virtual private networks (VPNs) to hide U.S. IP addresses. Most exchanges said they take steps, such as collecting personal information from users, to try to prevent such circumvention. The three foreign exchanges most commonly used by big TRUMP token holders to fund their accounts or buy TRUMP coins are Binance, Bybit and OOEX, all of which have imposed restrictions on U.S. users. A Bloomberg analysis found that six holders on the TRUMP token leaderboard made purchases on OOEX before the trading platform launched in the U.S. on April 15. A spokesperson for OOEX said the company did not allow U.S. residents to make purchases before then. Representatives for Binance and Bybit did not respond to requests for comment.
Two of the three exchanges have previously violated U.S. law. In November 2023, Binance pleaded guilty to violating federal anti-money laundering and sanctions laws due to poor internal controls and paid more than $4 billion to the United States. Ouyi pleaded guilty to anti-money laundering violations in February and paid more than $420 million.
This is not the first time that a Trump-related cryptocurrency project has attracted a large number of foreign investors.
Justin Sun, a Hong Kong-based cryptocurrency entrepreneur, became an advisor to the project after announcing he had purchased tens of millions of dollars worth of tokens of World Liberty Financial (WLF), another cryptocurrency project promoted by the Trump family. Sun said at the time that he did not expect to receive any benefits from Trump for the investment. Sun may also be a major holder of TRUMP tokens, according to a Bloomberg analysis of cryptocurrency wallet transactions.
Justin Sun, founder of blockchain platform TRON, in Hong Kong on May 8, 2020. Source: Bloomberg
World Liberty is promoting a stablecoin that will be used to facilitate transactions between Binance and an investment firm founded by the Abu Dhabi government, one of the company’s founders, Zach Witkoff, the son of Trump’s Middle East envoy, announced at a conference on Thursday. World Liberty executives did not respond to requests for comment.
“Congress should require the president to disclose those who are secretly paying him tributes to assess whether the public interest is being harmed,” said Tony Carrk, executive director of Accountable.US, a nonprofit that has set up an online “Trump Accountability War Room.” Accountable.US found that at least 14 of the top 50 holders of World Liberty tokens also used cryptocurrency services that are not accessible to Americans. A Bloomberg analysis found eight more such wallets. World Liberty disclosed in November that its initial $300 million offering was sold primarily overseas.
Many of the largest holders of WLF tokens are located abroad
Holdings of the top 50 wallets holding the most WLF tokens, by where the wallet holders are likely to be located. Data source: Accountable.US, Bloomberg analysis of Etherscan data. Note: Data as of 6:45 pm EST on April 30.
Trump, who once called Bitcoin a "scam against the dollar," has been deeply involved in the cryptocurrency field at a time when his administration has begun to dismantle regulatory and enforcement teams that were originally responsible for regulating these digital assets. For example, soon after he took office, the staff responsible for investigating cryptocurrencies at the U.S. Securities and Exchange Commission were reassigned and many of their cases were shelved. In April of this year, the U.S. Department of Justice disbanded its cryptocurrency task force.
Last month, Democratic Senators Adam Schiff and Elizabeth Warren called on the U.S. Office of Government Ethics in a letter to investigate the Trump Token Dinner promotion. They said the May 22 event posed “serious risks that President Trump and other officials could engage in corrupt conduct by selling access to the President to individuals or entities while personally enriching the President and his family.”
The Trumps benefited from the rise in the price of the TRUMP token because a company they control holds a large number of them. Although the Trumps cannot sell any tokens for a period of time under the terms of the token offering, any fluctuations in the price will change their wealth on paper. The announcement of the April 23 dinner caused the token price to rise from about $9 to about $14, and 436 new transactions of more than $100,000 occurred in the next five days, with the largest transactions involving accounts interacting with trading platforms that do not operate in the United States.
A surge in foreign purchases after the dinner was announced
Purchases of TRUMP tokens over $100,000 in April. Sources: Dune; Bloomberg analysis of SolScan data. Note: Data as of May 1.
To qualify for dinner with Trump, token holders must register for a "self-custodial" wallet, which is a wallet that is completely controlled by the holder rather than by a third-party exchange platform.
Bloomberg analyzed transactions for the top 220 wallets on the Dinner leaderboard as of May 5 to determine whether their holders might be from abroad. A separate analysis looked at all self-hosted wallets that held enough Trump tokens as of April 30 to qualify for the top 220. Many of the largest wallets are not listed on the Dinner leaderboard, suggesting they have not yet registered or that their time-weighted holdings may differ significantly from their current holdings. Some may be strategically waiting to register.
While it’s difficult to identify the people behind these accounts, there are public leads on some of them. Over the past few days, the entities on the leaderboard have been swapping places, with at least one of them boasting about it online. The wallet named “MeCo” belongs to an entity called “Memecore,” which describes itself as an “Ethereum Virtual Machine (EVM)-compatible L1 multi-chain cross-staking mainnet secured by the Meme Proof-of-Stake mechanism.”
“We’re not just going to top the TRUMP leaderboard, we’re going to conquer the entire Meme coin space,” the company said on Platform X. Memecore asks users to send it their TRUMP tokens in order to move up the rankings. The tokens will then be returned to users, along with rewards, the company said.
“The meme coin space is currently considered stagnant and we want to challenge that narrative,” Cherry Hsu, chief business development officer at Memecore, said in a statement on Telegram. “By participating in this event, we want to show that the meme coin space is on the rise again.”
The leader Memecore is chasing on the leaderboard chose the username "Sun" and used a wallet belonging to HTX, which is associated with Justin Sun, according to Bloomberg's analysis of blockchain data. Sun himself has publicly admitted to buying tokens from World Liberty Financial, but so far he has not stated whether he is the owner of the wallet at the top of the leaderboard. He did not respond to a request for comment.
The wallet labeled “Sun” began accumulating a total of $17.9 million worth of Trump tokens when they were initially launched in January. It has purchased an additional $4.5 million worth of tokens since the Trump dinner promotion was announced.
In 2023, the SEC sued Justin Sun, accusing him of working with companies he owned and controlled to plan the issuance and sale of unregistered securities. Sun's lawyers denied the allegations and said the regulator's claims were "too far-fetched and should be dismissed." In February of this year, after Sun spent at least $75 million to buy World Liberty Financial tokens, the SEC suspended its lawsuit against him, saying it was in the interest of both parties to consider potential solutions.
