# World Liberty Financial Regulatory File Every regulatory, congressional and legal action touching [[World Liberty Financial]], in one place. The detailed account of the charter approval itself is at [[World Liberty Trust OCC Bank Charter Approval]]; the regulator-wide context is at [[OCC Charter Wave]]. ## The trust charter: World Liberty Trust Company, N.A. - **Applicant:** WLTC Holdings LLC (sole shareholder). **Address:** 1177 Kane Concourse, Bay Harbor Islands, Florida. - **Filed:** January 5, 2026 (OCC public file); announced about January 7. - **Conditional approval:** **August 14, 2026**, 221 days after filing (OCC corporate decision #1385). That was the slowest crypto approval of Gould's tenure, against a 126-day median. - **Conditions** (from press accounts of the decision letter, which could not be retrieved directly): - At least **$20M Tier 1 capital**, with liquid assets of at least 50% of that or $10M, plus 180 days of operating expenses. - **No deposit-taking.** - ⚠️ **May not issue, custody or deal in WLF's own tokens** (American Banker, quoting the letter). - **Passivity commitments** from [[Eric Trump]] (as president of DT Marks), Hamad Khalfan Ali Matar Alshamsi (manager of StringZ Holdings RSC) and [[Zak Folkman]] (through AMGUS LLC): no board seats, no influence over the bank, and holdings above 9.9% voted by proxy through management. - The OCC's standard 18-month window to open (unverified for this letter). - **Ownership disclosed after approval:** WLTC Holdings is **49% StringZ Holding RSC** ([[Tahnoon bin Zayed]] and co-investors) and ⚠️ 38% a Trump-affiliated entity (WSJ, Aug 27, 2026). - **Since approval:** no capital raise, final approval, opening or change-in-control review reported as of October 8, 2026. ## Congress | Date | Who | Action | |---|---|---| | May 6, 2025 | Sen. [[Richard Blumenthal]] (Permanent Subcommittee on Investigations ranking member) | Inquiry letter to WLF | | Jan 13, 2026 | Sen. [[Elizabeth Warren]] | Asked the OCC to halt the review until the president divests | | ~Jan 23, 2026 | Comptroller [[Jonathan Gould]] | Declined, citing a duty to act in a timely manner | | Feb 4, 2026 | Rep. [[Ro Khanna]] (House Select Committee on China) | Opened a probe after the Aryam disclosure; March 1 deadline | | ~Feb 13, 2026 | Sens. Warren and [[Andy Kim]] | Asked Treasury whether [[CFIUS]] should review the Aryam stake | | Feb 19, 2026 | Rep. [[Gregory Meeks]] and House Democrats | Letter to Treasury Secretary [[Scott Bessent]] on the OCC review | | ~Feb 26, 2026 | Warren and Gould | Clashed at a Senate Banking hearing; Gould said he would "consider" her request | | Aug 15, 2026 | Warren and colleagues | Introduced the Ending Presidential Corruption in Banking Act | None of these can stop a charter. They put the record in place for a possible change in congressional control after the midterms. ## Litigation - **Sun v. World Liberty Financial** (N.D. Cal., filed Apr 21, 2026): [[Justin Sun]] sued over his frozen token rights. After an Aug 20, 2026 hearing, Judge Donato kept Sun's individual claims in open court rather than sending them to arbitration. WLF has countersued Sun for defamation in Florida. - **ICBA v. OCC** (D.D.C., filed Oct 2, 2026): the community bankers' challenge to the OCC's trust-bank rule. It does not name WLF, but if the rule falls, the legal basis for World Liberty Trust's charter is exposed. See [[OCC Charter Wave]]. ## Enforcement: none found No SEC, CFTC or DOJ action against WLF has been reported. On [[ALT5 Sigma]], watchdog groups asked the SEC to investigate in April 2026; an August 2026 FOIA response found no investigation records (POGO). ## Watch - Final approval or lapse of the trust charter - Any OCC change-in-control review of StringZ, and any CFIUS action on Aryam - Rulings in Sun's case and in ICBA v. OCC - Post-midterm subpoenas if the Senate or House changes hands ## See Also - [[World Liberty Trust OCC Bank Charter Approval]] · [[OCC Charter Wave]] · [[World Liberty Financial Dossier]] - [[World Liberty Financial UAE Sale]] · [[Emoluments Clauses]]