Implications of the National Trust Bank Charter for World Liberty Trust Co.
BriberyMatters has regularly covered increasing risks of corruption in the United States, tied both to recent regulatory and enforcement changes, and to President Trump’s extensive business interests. One issue took the headlines on August 11, when the Financial Crimes Enforcement Network (FinCEN) made permanent the rule ending beneficial ownership reporting for all domestic entities and US persons under the Corporate Transparency Act, and announced it would delete previously reported US-person information from its database. This decision, framed as relief for small businesses, carries real corruption risks, as I previously explored.
Then that same week, on August 14, a new concern emerged: the Office of the Comptroller of the Currency (OCC) granted preliminary conditional approval for a new national trust bank, World Liberty Trust Co. (WLTC). WLTC is closely tied to President Trump, his family and his business associates. WLTC shares indirect common owners with World Liberty Financial LLC, which sits within the Trump family's network of crypto ventures. WLTC plans to issue and custody World Liberty’s stablecoin, and is expected to be chaired by Zach Witkoff, a World Liberty co-founder and son of White House special envoy Steve Witkoff. Among WLTC's passive indirect investors is DT Marks SC LLC, whose president is Eric Trump.
It is important to be clear about what the OCC has granted. Crypto companies have increasingly sought OCC national trust bank charters, particularly after Congress passed the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act in July 2025. As lawyers have explained (for example, here and here), such charters offer crypto companies certain regulatory benefits while streamlining oversight. WLTC will not be eligible to make loans, accept deposits, or have Federal Deposit Insurance Corporation (FDIC) protection. But, as the Independent Community Bankers of America (ICBA) argues, such banks “avoid many prudential safeguards required of full-service banks.”
The OCC also made clear that to win final approval, WLTC must ensure compliance with the Bank Secrecy Act and Office of Foreign Assets Control (OFAC) requirements, and train staff in anti-money laundering. Still, the move sparked a quick response. Writing on X, Donald Sherman, President and CEO of Citizens for Responsibility and Ethics in Washington (CREW) called the approval "the most egregious example to date of the President's businesses profiting from his government job." Senator Elizabeth Warren and colleagues drafted the Ending Presidential Corruption in Banking Act, writing, “This is the most brazen act of self-dealing our financial system has ever seen.” Among other things, the Act (unlikely to advance in this Congress) seeks to “prohibit Presidents from owning or controlling banks”.
After WLTC applied for its charter in January 2026, the OCC received public comments about the President’s conflicts of interest, as well as World Liberty Financial’s links to foreign investors, which have been scrutinized in the media. The OCC sought to address these concerns in its preliminary approval, pointing out that World Liberty Financial, Inc. itself “is not a party to this application,” and its investors "would not have an investment in, or control over, the Bank."
Yet as noted earlier, the OCC also writes that WLTC shares indirect common owners with World Liberty Financial LLC. There is an important distinction at play: that LLC is separate from World Liberty Financial, Inc. The Inc.’s structure has been documented by the Center for American Progress, while the ownership of the LLC (and the identity of those indirect common owners) is not specified by the OCC. But regardless, the OCC does record the family tie to WLTC, running through DT Marks SC LLC. Thus while the OCC is technically accurate, it is clear that the same family is invested in both WLTC and the Inc.
The OCC’s assurances notwithstanding, a perception of potential conflict remains. Pending final approval, a sitting President will oversee a regulator that in turn will oversee a bank that will issue and custody the stablecoin of his own crypto venture. Structurally, the OCC, as a bureau of the Treasury Department led by a presidential appointee, is arguably less insulated from the White House than the Federal Reserve, which oversees traditional banks. The OCC did write in its conditional approval that career staff decided the matter "consistently with their statutory duties and ethical obligations," but it will be critical to track how the OCC's conditions are met, as well as how WLTC is supervised going forward.
Governance, Democracy and Economic Development Expert