Original title: Top Trump Crypto Buyers Vying for Dinner Seats Are Likely Foreign, Data Shows.
Original authors: Leonardo Nicoletti, Anthony Cormier, David Kocieniewski.
Original translation: Luffy, Foresight News.
Among the large holders of the Trump Meme coin, more than half are from foreign trading platforms that claim to ban U.S. users, indicating that many purchasers are from outside the U.S.
Trump is a cryptocurrency that President Trump began promoting just days before his inauguration. After an unprecedented promotional campaign, sales of the Trump token surged in the past two weeks: over 200 of the largest token holders will be invited to a dinner at Trump’s Virginia golf club on May 22, and the top 25 holders will qualify for an exclusive reception before the dinner and a 'VIP' tour described on the Trump token website.
Today, Bloomberg's analysis shows that among the top 25 holders registered on the website leaderboard, all but six 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 concerns raised by congressional Democrats about the ethical implications of promoting tokens with access to the president as a promise. This also raises questions about how participants in the promotional dinner will be vetted, as the public identities of these participants can only be linked to usernames consisting of a few letters.
Most large holders of the Trump token are likely based outside the U.S.
The current value of tokens held in 220 cryptocurrency wallets registered on the TRUMP leaderboard (by the possible location of wallet holders). The tokens held by the top 220 wallets are valued at 76% likely belonging to foreign owners, as these wallets use trading platforms inaccessible to U.S. residents. Data source: Bloomberg analysis of SolScan data. (Note: Data as of May 5 at 10 AM Eastern Time. Usernames are listed on the TRUMP token website, set by wallet holders upon registering to participate in the dinner promotion. One wallet still listed among the top 25 on the leaderboard is not included here as it nearly sold off all its holdings on May 3.)
In the website's details, the organizers stated that participants must pass a background check. The website reads: 'We will also review your wallet for KYC and compliance purposes. You will dine with the President of the United States!' However, the website did not specify how such checks would be conducted.
The promoters of the TRUMP token did not respond to requests for comment, nor did officials from the White House.
To appear on the dinner leaderboard, individuals who purchased TRUMP coins must register on its website, which claims to rank them based on the number of tokens held and the length of time held, though many large holders have yet to register. However, another Bloomberg analysis of all the largest buyers (regardless of whether they are on the leaderboard) shows that more than half of this broader buyer group also comes from foreign trading platforms.
It is possible that some U.S. buyers have found ways to bypass the ban by using foreign trading platforms, such as using virtual private networks (VPNs) to hide their U.S. IP addresses. Most trading platforms say they have taken measures like collecting users' personal information to try to prevent such circumvention. The three foreign trading platforms most commonly used by large TRUMP token holders to fund their accounts or purchase TRUMP coins are Binance, Bybit, and OKEx, all of which impose restrictions on U.S. users. Bloomberg's analysis found that before OKEx launched its trading platform in the U.S. on April 15, six holders on the TRUMP token leaderboard made purchases on that platform. A spokesperson for OKEx stated that the company did not allow U.S. residents to make purchases prior to that. Representatives from Binance and Bybit did not respond to requests for comment.
Two of the three trading platforms have previously violated U.S. laws. In November 2023, Binance pleaded guilty to violating federal anti-money laundering and sanctions laws due to internal control failures and paid over $4 billion to the U.S. OKEx admitted to violating anti-money laundering regulations in February, paying over $420 million.
Cryptocurrency projects related to Trump have attracted a significant number of foreign investors, and this is not the first time.
Justin Sun, a cryptocurrency entrepreneur in Hong Kong, became an advisor to another cryptocurrency project promoted by the Trump family, World Liberty Financial (WLF), after announcing the purchase of tens of millions of dollars worth of its tokens. Justin Sun stated at the time that he did not expect to gain any benefits from Trump due to this investment. According to Bloomberg's analysis of cryptocurrency wallet transactions, Justin Sun may also be a large holder of TRUMP tokens.
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 founders, Zach Witkoff, son of Trump's Middle East envoy, announced during a meeting on Thursday that this stablecoin will be used to facilitate a transaction 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 nonprofit Accountable.US, stated: 'Congress should demand the president disclose those who are secretly enriching him to assess whether the public interest is harmed.' The organization has set up a 'Trump 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 identified another eight such wallets. World Liberty disclosed in November that its initial $300 million issuance was primarily sold overseas.
Many large holders of WLF tokens are located abroad.
Holdings of the 50 wallets with the most WLF tokens (by the possible location of wallet holders). Data source: Accountable.US, Bloomberg 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,' has deepened his involvement in the cryptocurrency space while his administration has begun to dismantle regulatory and enforcement teams that were 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 of this year, 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 event on May 22 posed 'serious risks that President Trump and other officials may engage in corrupt behavior by selling access to the president to individuals or entities, while personally profiting for the president and his family.'
The Trump family benefits from the rise in TRUMP token prices, as a company they control holds a significant amount of these tokens. Although the Trump family is prohibited from selling any tokens for a period of time under the token issuance terms, any price fluctuations will alter their wealth status on paper. The announcement of the April 23 dinner caused the token price to rise from about $9 to approximately $14, leading to 436 new trades over $100,000 in the following five days, with the largest transactions involving accounts interacting with trading platforms not operating in the U.S.
A surge of foreign purchases occurred after the dinner announcement.
Purchases of TRUMP tokens exceeding $100,000 in April. Data source: Dune; Bloomberg analysis of SolScan data. Note: Data as of May 1.
To qualify for dinner with Trump, token holders must register a 'self-custody' wallet, which is fully controlled by the holder and not by a third-party trading platform.
Bloomberg analyzed trading data for the top 220 wallets on the dinner leaderboard as of May 5 to determine whether their holders might be from abroad. Another separate analysis examined all self-custody wallets that held enough Trump tokens to qualify for the top 220 as of April 30. Many of the largest holding wallets were not listed on the dinner leaderboard, indicating they may not have registered yet, or their time-weighted holdings may differ significantly from their current holdings. Some may be strategically waiting to register.
While it is difficult to identify the individuals behind these accounts, there are some public clues regarding some of them. Over the past few days, entities on the leaderboard have been swapping positions, with at least one entity boasting 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), secured by a Meme proof mechanism.'
The company stated on the X platform: 'We not only want to top the TRUMP leaderboard, but we also want to conquer the entire Meme coin space.' Memecore is asking users to send their TRUMP tokens to it to improve its ranking. The company stated that the tokens will be returned to users later, along with rewards.
Memecore's Chief Business Development Officer Cherry Hsu stated in a Telegram statement: '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, Memecore is chasing the leader on the leaderboard who chose the username 'Sun' and used a wallet belonging to HTX, which is associated with Justin Sun. Justin Sun himself publicly acknowledged purchasing tokens from World Liberty Financial, but he has not clarified whether he owns the top wallet on the leaderboard. He did not respond to requests for comment.
The 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 U.S. Securities and Exchange Commission sued Justin Sun, accusing him of collaborating with his owned and controlled companies to orchestrate the issuance and sale of unregistered securities. Justin Sun's lawyer denied the charges, stating that the agency's claims are 'far-fetched and should be dismissed.' In February, after Justin Sun spent at least $75 million purchasing World Liberty Financial tokens, the SEC paused its lawsuit against him, citing that considering potential resolutions is in the interest of both parties.
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