Over half of the major Trump Meme token holders come from overseas trading platforms that claim to ban US users, indicating that many buyers are from outside the United States.
Trump is a cryptocurrency that the former president began promoting days before his inauguration. After an unprecedented promotional campaign, Trump token sales have surged in the past two weeks: over 200 of the largest token holders will be invited to a dinner on May 22 at Trump's Virginia Golf Club, with the top 25 holders eligible to attend an exclusive pre-dinner reception 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 ranking, all except 6 used overseas trading platforms that claim not to accept US residents. Among the top 220 holders, at least 56% used similar offshore trading platforms. The widespread presence of these potential foreign buyers echoes congressional Democrats' moral concerns about selling tokens with promises of presidential contact. It also raises questions about how the promotional dinner participants will be vetted, with their public identities only linked to usernames composed of a few letters.
Most Trump Token Major Holders Likely Located Overseas
Current token value held by 220 crypto wallets registered on the TRUMP ranking (by potential wallet holder location). 76% of the token value held in the top 220 wallets may belong to foreign owners because these wallets use trading platforms unavailable to US residents. Data source: Bloomberg analysis of SolScan data. (Note: Data as of 10 AM Eastern Time on May 5. Usernames are set by wallet holders when registering for the dinner promotion on the TRUMP token website. One wallet still in the top 25 of the ranking website is not listed here because it almost completely sold its tokens on May 3)
In the website's fine print, organizers state that participants must pass a background check. The website reads: "We will also review your wallet for KYC and compliance purposes. You will have dinner with the US President!" However, the website does not specify how such a review will be conducted.
TRUMP token promoters did not respond to requests for comment, and White House officials did not respond either.
To appear on the dinner ranking, TRUMP token buyers must register on their website, which claims to rank them based on the number of tokens held and holding time, with many major holders not yet registered. However, another Bloomberg analysis of all major buyers (whether on the ranking or not) shows that over half of this broader buyer group also comes from overseas trading platforms.
It's possible that some US buyers have found ways to bypass restrictions by using overseas platforms, such as using virtual private networks (VPNs) to hide US IP addresses. Most trading platforms say they have taken measures like collecting user information to prevent such circumvention. The three most commonly used overseas platforms by TRUMP token major holders for funding accounts or purchasing TRUMP tokens are Binance, Bybit, and OKX, all of which impose restrictions on US users. Bloomberg's analysis found that 6 holders on the TRUMP token ranking made purchases on OKX before its US platform launch on April 15. An OKX spokesperson stated that the company did not allow US residents to purchase before that. Representatives from Binance and Bybit did not respond to requests for comment.
Two of these three trading platforms have previously violated US law. In November 2023, Binance pleaded guilty to poor internal controls violating federal anti-money laundering and sanctions laws, paying over $4 billion to the US. OKX admitted to violating anti-money laundering regulations in February and paid over $420 million.
This is not the first time a Trump-related crypto project has attracted significant foreign investment.
Justin Sun, a crypto entrepreneur from Hong Kong, became an advisor to the World Liberty Financial (WLF) token project after announcing the purchase of tokens worth tens of millions of dollars, promoted by the Trump family. Sun stated that he did not expect to receive any benefits from Trump for this investment. According to Bloomberg's analysis of crypto wallet transactions, Justin Sun may also be a major TRUMP token holder.
On May 8, 2020, Justin Sun, founder of the blockchain platform TRON, 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 on Thursday at a conference that this stablecoin would facilitate a transaction between Binance and an investment company founded by the Abu Dhabi government. World Liberty executives did not respond to requests for comment.
Tony Carrk, executive director of the non-profit Accountable.US, stated: "Congress should require the president to disclose those who are secretly paying tribute to him to assess whether public interest is being harmed." The organization has established a "Trump Accountability War Room" online. Accountable.US found that at least 14 of the top 50 WLF token holders also used crypto services inaccessible to Americans. Bloomberg's analysis discovered an additional 8 such wallets. World Liberty disclosed in November that its initial $300 million issuance was primarily sold overseas.
Many WLF Token Major Holders Located Overseas
Holding situation of the 50 wallets with the most WLF tokens (by potential wallet holder location). Data source: Accountable.US, Bloomberg analysis of Etherscan data. Note: Data as of 6:45 PM Eastern Time on April 30.
Trump, who once called Bitcoin a "scam against the dollar," is delving deeper into the cryptocurrency realm while his government has begun dismantling regulatory and enforcement teams originally responsible for overseeing these digital assets. For instance, shortly after taking office, SEC staff investigating cryptocurrencies were reassigned, with many of their cases shelved. In April this year, the US Department of Justice dissolved its cryptocurrency special task force.
Last month, Democratic Senators Adam Schiff and Elizabeth Warren wrote a letter urging the US Government Ethics Office to investigate the TRUMP token dinner promotion. They stated that the May 22 event poses a "serious risk that the former president and other officials might engage in corrupt behavior by selling opportunities to interact with the president to individuals or entities while personally profiting the president and his family".
The Trump family benefits from rising TRUMP token prices, as a company they control holds a large number of these tokens. Although token issuance terms prevent the Trump family from selling tokens for a period, any price fluctuations change their wealth on paper. The April 23 dinner announcement drove the token price from around $9 to about $14, with 436 transactions over $100,000 occurring in the following five days, with the largest transactions involving accounts interacting with non-US operating trading platforms.
Large Overseas Purchases Emerged After Dinner Announcement
TRUMP token purchases over $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-custodial" wallet, which is entirely controlled by the holder and not by a third-party trading platform.
Bloomberg analyzed the trading situation of the top 220 wallets on the leaderboard as of the evening of May 5th to determine if their holders might be from overseas. A separate analysis studied all self-custodied wallets that held enough Trump tokens to qualify for the top 220 as of April 30th. Many wallets with the largest holdings were not listed on the leaderboard, indicating they have not registered or their time-weighted holdings may differ significantly from current holdings. Some may be strategically waiting to register.
While it is difficult to identify the individuals behind these accounts, some public clues exist. In recent days, entities on the leaderboard have been exchanging positions, with at least one entity boasting about this online. The wallet named "MeCo" belongs to an entity called "Memecore", which describes itself as an "EVM-compatible L1 multi-chain cross-staking mainnet protected by a Meme proof mechanism".
The company stated on X platform: "We not only want to be at the top of the TRUMP leaderboard, but we also want to conquer the entire Meme coin domain." Memecore requires users to send their TRUMP tokens to it to improve ranking. The company says tokens will be returned to users later with rewards.
Cherry Hsu, Memecore's Chief Business Development Officer, stated on Telegram: "Currently, the Meme coin domain is considered stagnant, and we want to challenge this claim. By participating in this event, we want to demonstrate that the Meme coin domain is rising again."
According to Bloomberg's blockchain data analysis, 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. Justin Sun publicly acknowledged purchasing World Liberty Financial tokens, but so far has not clarified whether he is the owner of the top-ranked wallet. He did not respond to requests for comment.
The wallet marked "Sun" began accumulating tokens worth a total of $17.9 million when Trump tokens were initially launched in January. Since the Trump dinner promotion was announced, it has purchased an additional $4.5 million in tokens.
In 2023, the U.S. Securities and Exchange Commission sued Justin Sun, alleging he collaborated with companies he owned and controlled to plan the issuance and sale of unregistered securities. Justin Sun's lawyers denied these allegations, stating the regulator's claims were "far-fetched and should be dismissed". In February, after Justin Sun spent at least $75 million purchasing World Liberty Financial tokens, the SEC suspended the litigation, saying considering potential solutions was in both parties' interests.
