Among Trump meme coin holders, over half 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, and the top 25 holders will be 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, 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 promising contact with the president. It also raises questions about how the promotional dinner participants will be vetted, with their public identities only linked to usernames consisting of a few letters.
Most Trump Token Holders Likely Outside the US
Current token value held by 220 cryptocurrency wallets registered on the TRUMP leaderboard (based on potential owner locations). 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's 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 in the top 25 of the leaderboard is not included here because it almost completely sold its tokens on May 3)
In the website's terms, 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 also did not respond.
To appear on the dinner leaderboard, TRUMP coin buyers must register on their website, which ranks them based on token quantity and holding time, with many large holders not yet registered. However, another Bloomberg analysis of all major buyers (whether on the leaderboard or not) shows that over half of this broader buyer group also comes from overseas trading platforms.
Some US buyers might have found ways to bypass restrictions using foreign trading 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 foreign platforms most commonly used by TRUMP token large holders to fund accounts or purchase TRUMP coins are Binance, Bybit, and OKX, all of which restrict US users. Bloomberg's analysis found that 6 leaderboard holders 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 time. 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 cryptocurrency project has attracted significant foreign investment.
Crypto entrepreneur Justin Sun, after announcing the purchase of tokens worth millions from another Trump family-promoted cryptocurrency project, World Liberty Financial (WLF), became an advisor to the project. Justin Sun stated at the time that he did not expect any benefits from Trump for this investment. According to Bloomberg's analysis of cryptocurrency wallet transactions, Justin Sun may also be a large TRUMP token holder.
World Liberty is promoting a stablecoin. Zach Witkoff, one of the company's founders and Trump's Middle East envoy's son, announced on Thursday at a conference that this stablecoin will 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 secretly paying tribute to him to assess whether public interest is compromised." The organization has established a "Trump Accountability War Room" online. Accountable.US found that at least 14 of the top 50 WLF token holders used cryptocurrency 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 Holders Are Located Overseas
Trump, who once called Bitcoin a "scam against the dollar," is delving deeper into the cryptocurrency space 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 carries a "serious risk that President Trump and other officials might engage in corrupt behavior by selling opportunities for personal contact, personally profiting the president and his family."
The Trump family benefits from TRUMP token price increases, 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.
Significant Overseas Purchases After Dinner Announcement
To qualify for dinner with Trump, token holders must register a "self-hosted" wallet, which is entirely controlled by the holder, not a third-party trading platform.
Bloomberg analyzed transaction details of the top 220 wallets on the dinner leaderboard as of May 5 to determine potential foreign origins. A separate analysis studied all self-hosted wallets with sufficient Trump tokens to qualify for the top 220 as of April 30. Many of the largest holding wallets are not listed on the dinner leaderboard, suggesting they have not registered or their time-weighted holdings may differ significantly from current holdings. Some may be strategically waiting to register.
Although it is difficult to identify the individuals behind these accounts, some public clues exist for certain entities. In the past few days, the 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 "L1 multi-chain cross-staking mainnet compatible with the Ethereum Virtual Machine (EVM), 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 them to improve their ranking. The company says the tokens will be returned to users later with rewards.
Cherry Hsu, Chief Business Development Officer of Memecore, 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 belonging to HTX, which is associated with Justin Sun. Justin Sun has publicly acknowledged purchasing World Liberty Financial tokens, but so far, he 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 the Trump tokens were initially launched in January. Since the Trump dinner promotion was announced, 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 companies he owns and controls to plan the issuance and sale of unregistered securities. Justin Sun's lawyers denied these allegations, stating that 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 lawsuit against him, saying that considering potential solutions was in the interest of both parties.
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