"The bank plans to provide its digital asset custody services as a fiduciary, primarily to USD1 customers and other institutional clients," the decision letter read. "The bank's conversion services would allow custody customers to submit approved stablecoins to the bank in exchange for USD1."
USD1, the dollar-backed stablecoin launched by World Liberty last year, has reached over $4 billion in circulation, according to a company statement.
"A national trust bank brings USD1 issuance, custody, and reserve management together under OCC supervision, examined on the same standards that have governed banks for generations," World Liberty co-founder Zach Witkoff, son of presidential envoy Steve Witkoff, said in a statement. Witkoff is also the proposed president of World Liberty Trust Company.
The trust company will be governed by a five-member board: Zach Witkoff, who will serve as chairman, of World Liberty Financial; Scott Alper, president and chief investment officer of Witkoff Group; Robert Witkoff, brother of Steve Witkoff and former co-chief investment officer of property and casualty insurer Chubb Corporation; Jeffrey Weiner, CEO of Integrity Automotive and former chairman and CEO of accounting firm Marcum LLP; and Erin Baskett, member of the FINRA Board of Governors and founder of brokerage firm Sine Qua Non Capital.
Americans for Financial Reform Education Fund, a consumer nonprofit lobbying group, published a statement opposing the conditional approval Friday evening "because WLF Trust will not fulfill the fiduciary requirement for trust bank charters, based on WLF's business relationships with convicted money-launderers (some subsequently pardoned by Trump) and foreign investors."
The statement went on to say that "granting this charter threatens financial stability — with conflicted regulators unwilling or unable to act — while inevitably enriching the Trump family crypto empire. The endemic crypto volatility, fraud, crime, and corruption will only become further entrenched in the financial system, increasing the risks of another financial crisis."
In the decision letter posted Friday, the OCC responded to conflict of interest concerns raised by public commenters and lawmakers during the review process.
"The Comptroller and staff acted consistently with their statutory duties and ethical
obligations with respect to the application," the letter read. "Approvals of applications such as this are made under authority delegated by the Comptroller to career staff. Career OCC staff, including those who have reviewed this application and those who will be responsible for supervising the bank, receive regular training and information on the many different avenues available to them to raise concerns related to ethics or personnel issues, as well as the legal and ethical responsibilities to which they are subject. OCC staff reviewed this application in
accordance with the agency's established policies and procedures."
As one of the conditions for the approval, according to the decision letter, World Liberty Trust Company must maintain a minimum of $20 million in tier 1 capital with at least 50% of it in eligible liquid assets, such as cash or government obligations maturing within 90 days or less.
The decision letter also included three passivity commitments — formal pledges from a bank shareholder to a regulator stating they will not try to control or influence a bank — submitted to the OCC as part of the review process.
The individuals and firms that filed passivity commitments regarding World Liberty Trust Company were Eric Trump, Donald Trump's son and president of World Liberty majority stakeholder DT Marks (a holding company 70% owned by Donald Trump Revocable Trust and 30% owned by members of the Trump family); Hamad Khalfan Ali Matar Alshamsi, a UAE entrepreneur and manager of StringZ Holdings RSC; and Zachary Folkman, co-founder of World Liberty Financial and managing member of AMGUS LLC.
All three entities agreed in the passivity commitment filings to not seek board representation, access material nonpublic information or influence the bank's pricing, investment, personnel and operating decisions.
