Written by: KarenZ, Foresight News

A preliminary conditional approval letter has brought the trust bank plan of World Liberty Financial into the spotlight; two weeks later, the equity structure revealed Abu Dhabi royal family capital entering the picture.

On August 14, the Office of the Comptroller of the Currency (OCC) preliminarily conditionally approved the establishment of World Liberty Trust Company, N.A. (WLTC). This national trust bank, still in preparation, plans to take over the issuance, redemption, and management of the stablecoin USD1.

Two weeks later, public attention shifted from what services the bank plans to offer to who is funding the bank.

Equity Exposure: Abu Dhabi Capital Enters Bank Holding Layer

On August 27, The Wall Street Journal cited informed sources revealing that UAE National Security Advisor and Abu Dhabi royal family member Sheikh Tahnoon bin Zayed al Nahyan (Tahnoon) and co-investors hold 49% of WLTC Holdings through StringZ Holding RSC; an entity associated with the Trump family holds another 38%.

It should be noted that the specific proportions of 49% and 38% come from interviews with informed sources by The Wall Street Journal; the OCC documents do not disclose the precise ownership percentages of each shareholder.

However, OCC documents confirm two key facts in this structure:

First, the proposed WLTC will be wholly owned by Delaware company WLTC Holdings LLC. WLTC is the entity applying for the national trust bank license, while WLTC Holdings is the holding company above the bank, with investors indirectly holding bank equity through this holding layer.

Second, StringZ Holding RSC (DE) LLC, DT Marks SC LLC, and AMGUS, LLC all have indirect investments in the proposed bank and submitted passive investment commitments to the OCC.

Therefore, this transaction involves at least two layers: WLTC is responsible for applying for the license and operating the bank, while WLTC Holdings is responsible for holding WLTC and absorbing the investments from various shareholders.

The Same Royal Family Member, Two Different Investment Vehicles

Sheikh Tahnoon bin Zayed al Nahyan (Tahnoon) is the brother of UAE President Mohammed bin Zayed al Nahyan, currently serving as the Deputy Ruler of Abu Dhabi and UAE National Security Advisor. He also chairs various institutions, including MGX, artificial intelligence group G42, Abu Dhabi Investment Authority (ADIA), and First Abu Dhabi Bank.

This means that Tahnoon holds triple identities as a royal family member, a senior government official, and a large capital manager. The investment landscape he manages or influences spans artificial intelligence, semiconductors, finance, energy, and digital assets, with MGX being an important platform dedicated to investing in artificial intelligence and advanced technologies.

Tahnoon's business relationship with World Liberty Financial can be traced back to before Trump's second inauguration. According to earlier disclosures by The Wall Street Journal, the Abu Dhabi investment vehicle Aryam Investment 1, supported by Tahnoon, plans to invest $500 million to acquire a 49% stake in World Liberty Financial by January 2025. Of the initial payment of $250 million, about $187 million flowed to entities controlled by the Trump family, and at least $31 million went to entities associated with the Witkoff family.

The Witkoff family is from the U.S. real estate industry, with core figure Steve Witkoff being the founder of Witkoff Group and the current U.S. special envoy for Middle East affairs and peace missions under the Trump administration, who was involved in the early founding of World Liberty Financial. Project documents indicate that after entering government, he was designated as a "retired co-founder" of World Liberty Financial. His sons Zach Witkoff and Alex Witkoff are both co-founders of World Liberty Financial, with Zach Witkoff currently serving as CEO.

According to announcements made by World Liberty Financial, Zach Witkoff will also serve as the chairman of the WLTC board.

This bank investment used another entity, StringZ. In other words, Aryam Investment 1 corresponds to the previous investment in World Liberty Financial, while StringZ is used to hold the equity related to WLTC bank holding company. Both are supported by the same Abu Dhabi royal family member but are not the same legal entity.

A Passive Investment Commitment, How to Restrict Shareholders?

The full name in OCC documents is StringZ Holding RSC (DE) LLC. OCC attachments show that the passive investment commitment from StringZ was signed by the company manager Hamad Khlfan Ali Matar Alshamsi.

DT Marks SC LLC, which appears alongside StringZ in the OCC documents, is also an investment entity related to the Trump family. The passive investment commitment for this company was signed by Eric F. Trump, son of Trump, in his capacity as president, directly confirming the management relationship between DT Marks SC and Eric Trump.

It is also necessary to distinguish between two similarly named entities:

• DT Marks SC LLC appears in WLTC bank approval documents as a direct or indirect investor in the proposed bank or its holding company.
• DT Marks DEFI LLC appears in previous legal disclosures of World Liberty Financial, holding about 38% of WLF Holdco LLC and possessing some economic rights related to WLFI tokens and agreements.

Both entities are related to the Trump family but correspond to bank investment and the original business of World Liberty Financial respectively, and should not be conflated.

The commitments submitted by StringZ, DT Marks SC, and AMGUS are basically identical. None of the three companies may seek a board seat at the bank, obtain significant non-public information, or influence the bank’s pricing, personnel, investments, and operational policies.

If any entity obtains 10% or more of any type of voting shares, any voting rights exceeding 9.9% must be delegated to the bank’s management.

This arrangement separates economic interests from operational control rights. Even if the 49% stake ratio reported by The Wall Street Journal is accurate, StringZ cannot obtain the same proportion of voting rights, nor can it directly appoint directors or intervene in the bank’s daily management. However, the passive investment commitment restricts control rights but does not automatically negate investors' economic benefits from share profits and asset appreciation.

What Kind of "Bank" is WLTC?

The scope of business for World Liberty Trust Company, N.A. (WLTC) is distinctly different from that of ordinary commercial banks.

According to the OCC approval documents, WLTC will be a limited-purpose national trust bank without FDIC deposit insurance. Its business plan focuses on stablecoins and digital asset services, rather than traditional deposit and loan services offered by commercial banks to retail customers. WLTC also currently does not plan to apply for a Federal Reserve master account and has promised not to issue, custody, or trade WLFI governance tokens.

Upon final approval and official opening, WLTC plans to engage in three core types of business:

• Issuing and redeeming USD1 for institutional clients across the U.S. and managing the reserve assets of USD1;
• Custodying digital assets for institutional clients in a fiduciary capacity;
• Providing conversion services between authorized stablecoins and USD1 for custody clients.

Currently, the exclusive issuer and custodian of USD1 is BitGo Bank & Trust. WLTC plans to take over the reserve assets and related liabilities of USD1 once established, consolidating the issuance, redemption, reserve management, and institutional custody into a trust bank subject to direct OCC supervision.

However, WLTC cannot open yet. The OCC has only provided a "preliminary conditional approval" and reserves the right to modify, suspend, or revoke this decision before final approval.

WLTC must also maintain at least $20 million in Tier 1 capital, establish compliance with anti-money laundering, sanction screening, and client information security systems, submit a complete information system and operational framework, and pass pre-opening inspections in order to obtain final approval.

If WLTC fails to raise sufficient capital within 12 months after preliminary approval, or fails to officially open within 18 months, this approval will, in principle, expire. World Liberty Financial also referred to this approval as a node in a multi-stage bank license process in its announcement.

On One Side is the Bank License, On the Other is the Question of Conflicts of Interest

Tahnoon’s connection to World Liberty Financial also extends to Binance through USD1.

In March 2025, MGX, chaired by Tahnoon, announced an investment of $2 billion in Binance in exchange for a minority stake. MGX only stated at the time that the transaction was settled using stablecoins, without disclosing the stablecoin name. On May 1, World Liberty Financial co-founder Zach Witkoff announced at the Token2049 conference in Dubai that MGX was using USD1, which was launched shortly before. Bloomberg later reported this news.

This transaction quickly expanded the circulation of USD1 and intensified scrutiny of the relationships between Abu Dhabi capital, the Trump family's economic interests, and U.S. cryptocurrency policy.

Senators in the U.S., including Elizabeth Warren, subsequently requested MGX, Binance, and World Liberty Financial to provide relevant communication records, and also requested the OCC to suspend the bank license review for World Liberty Financial until Trump and his family divest from related economic interests.

The OCC responded to requests for suspension or rejection of the application in the approval documents but still granted WLTC preliminary conditional approval. The document stated that the application was reviewed by OCC professional staff in accordance with established procedures and relevant statutory, regulatory, and policy standards.

Regarding concerns about the purchase of WLFI tokens, potential conflicts of interest, and the U.S. Constitution's Compensation Clause, the OCC stated that since World Liberty Financial and its foreign investors are not parties to this bank license application, these issues are beyond the scope of this review. The OCC also indicated that whether the Committee on Foreign Investment in the United States (CFIUS) reviews World Liberty Financial's equity and foreign investments is similarly outside the scope of this license review; other policy concerns are also insufficient to constitute grounds for rejecting the application.

According to The Block, the White House denied that there is a conflict of interest in the transaction.

Moving forward, attention needs to be paid to whether the OCC will issue final opening approval, whether WLTC will disclose more complete shareholder information, and how the reserve assets of USD1 will be transferred from BitGo to the new bank, along with how related transactions and profit distributions will be disclosed.

A bank license can define how WLTC operates and constrain how shareholders exert control. However, as long as the investment relationships are not fully disclosed, the questions surrounding these shareholders will not automatically disappear with a mere approval.

What follows is to observe whether the OCC will issue final opening approval, whether WLTC will publish a complete shareholder register, and how WLTC will disclose related transactions, shareholder profits, and potential conflicts of interest after the transfer of USD1 reserve assets from BitGo to the new bank.

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