OCC Grants World Liberty Trust Company Preliminary Conditional Approval, Resolving Trump-Family and Emirati Ownership Questions Through Signed Passivity Commitments

Opening paragraph

On August 14, 2026, the Office of the Comptroller of the Currency granted preliminary conditional approval to charter World Liberty Trust Company, National Association (Bay Harbor Islands, Florida), a wholly owned subsidiary of WLTC Holdings LLC. The approval letter — Corporate Decision #1385, signed by Senior Deputy Comptroller for Chartering, Organization & Structure Stephen A. Lybarger — resolves the conflict-of-interest and foreign-ownership objections raised in the public comment record not by divestiture and not by examining the ownership of World Liberty Financial, but through three executed passivity commitments dated June 13, 2026, one of them signed by Eric F. Trump and one by an Emirati manager, in which each investor promises not to exercise control over the bank. This closes the decision window documented in 2026-05-06–wltc-occ-charter-pre-decision-baseline — 219 days after the January 7, 2026 filing, not the 120-day target.

What Happened / Key Facts

The action is preliminary, not final — and the document insists on the distinction. The letter states: “The OCC has granted preliminary conditional approval only. Final approval and authorization pursuant to 12 USC 27(a) for the Bank to commence business will not be granted until all preopening requirements are met. Until final approval is granted, the OCC has the right to modify, suspend, or rescind this preliminary conditional approval should the OCC deem any interim development to warrant such action.” World Liberty Trust Company is not chartered and is not open; it has cleared the first of at least two gates, and must carry “In Organization” after its name in all official documents until it opens. Any reporting that says the OCC “approved World Liberty’s bank” without this qualifier overstates the document.

The bank would take USD1 issuance away from BitGo. Per the letter’s own description of proposed activities, the Bank “plans to issue USD1, a fiat currency-backed stablecoin, to institutional clients on a nationwide basis, assuming this role from BitGo Bank & Trust, National Association (BitGo), the current exclusive issuer and custodian for USD1.” Proposed activities are: dollar-backed stablecoin issuance, redemption and reserve maintenance in a nonfiduciary capacity; digital asset custody as a fiduciary; and conversion services letting custody customers exchange approved stablecoins for USD1.

A Federal Reserve master-account step is written into the approval. The OCC granted approval “with the understanding that the Bank will apply for stock in a Federal Reserve Bank in accordance with 12 USC 222” (citing 12 CFR 209.2). The pre-decision baseline flagged Fed access as the key downstream question; the approval document makes the application an express premise of the OCC’s decision.

The three passivity commitments — the mechanism. The letter states the approval “is based on the representations, submissions, and information available to the OCC as of this date, including the passivity commitments dated June 13, 2026, which are attached as an exhibit to this letter.” Three parties executed them:

Each commits that its direct or indirect investments in WLTC NTB, WLTC Holdings, or any company controlling them will be passive. The enumerated prohibitions include: not causing the Bank to become a subsidiary; not placing any representative as officer, agent, or employee; not proposing an opposing slate of directors; not seeking or using material non-public information; not communicating with directors, officers or employees “for the purpose of (i) influencing or directing management decisions or policies, or (ii) controlling or attempting to control a Bank”; not attempting to influence dividend policy, investment decisions, service pricing, personnel decisions, or the location of offices; not soliciting proxies; and not pledging the acquired shares to secure a loan. Any acquisition of 10% or more of a class of the Bank’s securities “will be exclusively for investment purposes,” and no representative may sit on the board “including in a non-voting, observational, advisory, or similar capacity.” The DT Marks instrument states that if the commitments “are not strictly adhered to, DT Marks will have intentionally exercised a controlling interest in the Bank and, therefore, will be subject to administrative action by the OCC.”

The OCC’s answer to the UAE-ownership objection is a party-status argument. Commenters urged that CFIUS review World Liberty Financial’s ownership and Emirati investment before approval. The OCC declined on jurisdictional-scope grounds, writing: “World Liberty Financial, Inc., is not a party to this application, and investors in World Liberty Financial, Inc., would not have an investment in, or control over, the Bank. Reporting on foreign purchases of the WLFI token and investments into World Liberty Financial, Inc., has been open and extensive, and CFIUS review is outside of the scope of the OCC’s review of this application.” Elsewhere the letter records that “four commenters expressed concerns about potential conflicts of interest involving the Bank, President Donald J. Trump and his family, Alexander and Zachary Witkoff, and United Arab Emirati investors in World Liberty Financial, Inc.,” and that three suggested the Bank could receive preferential treatment because the Comptroller is a presidential appointee.

Named entities absent from prior canon. The corpus held no file on StringZ Holding RSC (DE) LLC, on Hamad Khlfan Ali Matar Alshamsi, on Bay Harbor Islands as the proposed main office, or on the passivity-commitment mechanism itself. “RSC” is a Ras Al Khaimah corporate form; the entity’s relationship to the previously tracked Aryam Investment 1 / G42 thread is not established by this document and should not be assumed. The applicant contact of record is Brandi Reynolds of SC Financial Technologies, LLC, 4400 Biscayne Blvd, Miami — not World Liberty Financial itself.

Timing, stated as a type. August 14, 2026 is the date on the signed approval letter (a primary-document date). The OCC’s own 120-day target from the January 7, 2026 filing would have fallen near May 7, 2026; the actual decision came 219 days after filing.

Why This Event Matters

The pre-decision baseline called this “the single highest-leverage regulatory event in Investigation 4.” The outcome shows the structure by which the conflict was cleared, and the structure is the finding: the ownership question was never adjudicated — it was contracted around. The OCC did not determine who ultimately owns World Liberty Financial, did not require divestiture by the president’s family, and expressly placed foreign-investment review outside its scope on the ground that the parent “is not a party to this application.” What it obtained instead was a set of promises, signed by the president’s son among others, that the owners will not do the things owners do.

Function, not intent: whatever the OCC’s supervisory rationale, the conversion this performs is to take a live question about foreign and presidential-family control of a federally supervised stablecoin issuer and convert it into an enforcement contingency — a violation to be detected after the fact, by a regulator whose Comptroller is a presidential appointee, using information the regulated parties have promised not to seek. Whether the passivity commitments bind in practice is exactly the thing that cannot be observed from outside.

Research Gaps

• StringZ Holding RSC (DE) LLC — beneficial ownership, Ras Al Khaimah registration, and whether it is related to the Aryam Investment 1 / G42 thread tracked since February 2026. Do not assume the connection; establish it from a registry.
• AMGUS, LLC — Delaware/Florida registration and its relationship to Zachary Folkman’s other WLF-affiliated entities.
• The June 13, 2026 date on the passivity commitments — two months before approval. What happened between June 13 and August 14?
• Federal Reserve stock application under 12 USC 222 — filed? Docketed? This is the master-account path.
• BitGo transition — the terms under which BitGo Bank & Trust cedes exclusive USD1 issuance and custody.
• Whether a final approval under 12 USC 27(a) has been granted, and the 12-month capital / 18-month opening expiry clock.

Related Entries

• 2026-05-06–wltc-occ-charter-pre-decision-baseline
• 2026-01-07–world-liberty-financial-occ-bank-charter-application
• 2026-01-13–warren-presses-occ-halt-wlfi-bank-charter
• 2026-01-23–occ-rebuffs-warren-wlfi-charter-delay
• 2026-02-09–ncrc-afref-comment-letters-wltc-charter
• 2026-04-01–occ-12-cfr-5-20-amendment-trust-bank-chartering-rule-effective
• 2026-08-17–treasury-genius-act-section-3-stablecoin-nprm-criminal-penalties

Date correction, 2026-08-31 — the OCC document carries TWO dates for the same instrument. A research pass found that Corporate Decision #1385 states the passivity commitments were made “in a letter dated July 13, 2026” (in the Regulation W / asset-purchase discussion) while its Conclusion relies on “the passivity commitments dated June 13, 2026, which are attached as an exhibit.” Both appear verbatim in the primary document, in different sections. This is an internal inconsistency in the OCC’s own text, not a transcription error on either side, and it is unresolved by anything in the document. Cite it as such — do not silently pick one. (This conductor initially wrote June 13 as settled; a literal-string grep for “June 13, 2026” returns zero on extracted text because a line break falls between “13,” and “2026” — the whitespace-normalized text carries both.) The document also spells the entity both “StringZ Holding RSC (DE) LLC” (3×) and “StringZ Holdings RSC (DE) LLC” (1×).