Banking and Finance Law Daily Wrap Up, FINANCIAL TECHNOLOGY—AFREF opposes Trump family crypto company bid for a national bank charter, (Feb 11, 2026)

By A. Bryan Gerepka

The group argues that WLF’s business model does not fall within the bounds permitted by this type of charter, and the application raises serious conflicts of interest and corruption concerns.

Americans for Financial Reform Education Fund (AFREF) urged the Office of the Comptroller of the Currency to reject World Liberty Financial, Inc.’s (WLF) application to create a wholly-owned crypto national trust bank subsidiary, arguing that WLF’s business model does not meet the statutory requirements of a national trust bank charter. Moreover, AFREF continued, the application raises grave concerns of conflicts of interest and corruption, due to the company’s ties to President Trump’s family and friends, as well as several foreign investors.

On Jan.5, 2026, WLF applied to the OCC for a national trust bank charter to create World Liberty Trust Company (WLTC), National Association, an uninsured national bank/Federal savings association. In a Feb. 9, 2026, letter to the OCC, AFREF called on the regulator to reject the application, labelling the 30-day comment period inadequate for the public to provide meaningful comments on such a new and complex institution. The group also outlined several risks to awarding WLTC a national bank charter. They include:

• Conflicts of interest related to the Trump family’s ties to WLF, as well as foreign investments in WLF and involvement with other Trump family crypto ventures.

• Failure to meet high fiduciary standards that are traditionally expected of national trust banks. WLFC will issue stablecoins, manage stablecoin reserves, and provide unnamed digital asset custody for customers to hold and trade cryptocurrencies, the group stated. This is a much wider scope of activities, including activities where the proposed WLTC would not be guided by the best interests of most retail customers, the group added.

• Lack of Traditional Consumer Protections, as WLTC’s uninsured accounts may mislead customers into believing that their deposits are insured. In addition, AFREF stated that WLF’s platform has been hit in the past by fraud and phishing attacks, leaving consumers exposed to potential losses.

• Foreign investors in WLF, especially politically exposed persons, create unique conflicts of interest and national security risks, and heighten the potential for government corruption.

• Detrimental Community Impact. WLTC has failed to propose a plan to meet the Federal banking regulations that require banks to meet the convenience and needs of their communities. In addition, the shift from insured bank deposits to stablecoins could deprive community banks of the source of funds to support local loan activity.

• Violations of anti-money laundering regulations due to WLF’s ties to various partnerships and foreign actors, which may limit the ability to combat illicit financings.

• Heightened systemic financial risks related to crypto finance trading activities, especially if WLTC becomes a member of the Federal Reserve and has access to emergency credit.

If the application is approved, AFREF noted that WLF would gain access to all the benefits of being a publicly chartered bank, such as Federal Reserve System membership, discounted credit costs, and even emergency bailout lines of credit, without the appropriate oversight and supervision. The Federal Reserve system would confer unfair advantages and emergency public support to an uninsured crypto bank, the group stated.

Conflicts of interest. AFREF questioned the regulators’ ability to impartially evaluate an application that is related to the Trump family's crypto ventures. “There is every reason to fear that President Trump’s banking officials will rubber-stamp a highly-profitable giveaway to the First Family’s crypto company that creates serious risks for both economic stability and national security,” said Patrick Woodall, managing director for policy at Americans for Financial Reform. “The conflicts of interest are unprecedented.” Moreover, recent reporting in the Wall Street Journal revealed that the sovereign wealth fund chaired by United Arab Emirates (UAE) royal Sheik Tahnoon bin Zayed Al Nahyan holds a 49 percent stake in WLF, and two of the fund’s officers sit on the WLF board. This large WLF foreign controlling interest would effectively give the UAE royal family control over the proposed new crypto bank, the group warned.

Treasury should review foreign investment. AFREF continued, the recently disclosed foreign control of the WLF requires the Treasury Department to consider and evaluate the application under the Committee for Foreign Investment in the United States statutes. AFREF also called for the OCC to postpone consideration of the WLTC application until the foreign owners divest their controlling holdings in WLF.

Crypto bank requires Fed supervision. A novel crypto bank and bank charter that is controlled by foreign investors must be considered a bank holding company under federal law, which would require Fed approval, as well as require consolidated supervision of the WLF and the proposed WLTC subsidiary, AFREF stressed.

In summary, the OCC and Federal Reserve must reject WLTC’s application because it fails to meet the statutory requirements for national trust banks and bank holding companies, AFREF wrote. It would impermissibly commingle commerce and banking, it would amplify risks to the financial system and the broader economy, it would not meet the convenience and needs of customers or communities, and it would pose substantial risks of non-compliance with money laundering laws, the group concluded.

Companies: Americans for Financial Reform; Americans for Financial Reform Education Fund; World Liberty Financial, Inc.

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