$WLFI Crypto-Asset White Paper under MiCA
Reporting cited here
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Reuters reported that an entity calling itself Aqua 1 Foundation and saying it was UAE-based announced a $100 million WLFI purchase. Reporters could not verify its claimed principals, office, or regulatory registration; because World Liberty's terms send 75% of new token proceeds to the Trump family, Reuters said the purchase injected tens of millions of dollars into the family's personal coffers.
Part D.5 and related-party sections listing WLF co-founders, supporters, token allocations, and affiliated entitiesAqua 1 bought $100 million of WLFI while its owners remained opaque · Investment announced; beneficial ownership unresolved in reviewed reporting
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Donald Trump signed the GENIUS Act on July 18, 2025. Section 4(i)(2) says the act does not limit existing ethics law and states that existing rules prohibit any member of Congress or senior executive-branch official from issuing a payment stablecoin while in public service; the enacted clause contains no express restriction on a president's relatives. AP reported that Trump's family held a significant stake in World Liberty Financial, issuer of a dollar-pegged stablecoin.
Part D.5 and related-party sections listing WLF co-founders, supporters, token allocations, and affiliated entitiesGENIUS Act ethics clause omitted a presidential-family issuer bar · Enacted; no express family-member issuer restriction in Section 4(i)(2)
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ALT5 Sigma's SEC filing reports two distinct August 12 transactions: institutional investors paid $750 million cash for registered shares, while World Liberty Financial transferred $750 million of WLFI tokens, valued at $0.20 each, in exchange for private-placement shares and pre-funded warrants. ALT5 said up to $10 million of the registered offering's net cash could fund litigation, debt, and existing operations, with the balance designated for WLFI purchases and treasury operations; the filing identified Eric Trump as a World Liberty Financial co-founder.
Part D.5 and related-party sections listing WLF co-founders, supporters, token allocations, and affiliated entitiesALT5 closed a $750 million cash offering and a $750 million WLFI token placement · Offerings closed and WLFI treasury strategy initiated
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WLF's Gold Paper says Zachary Folkman and Chase Herro wholly own AMG, which together with WC Digital Fi received 7.5 billion $WLFI and rights to 25% of net protocol revenue. WLF's MiCA paper separately says the issuer raised more than $550 million in token sales. Neither source states Folkman's personal distribution.
Part A.17, pages 10–11Folkman-Herro entity shares a 7.5 billion-token and 25% revenue allocation · AMG and WC Digital Fi held the disclosed collective allocation
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World Liberty Financial's MiCA paper lists Zachary Folkman as co-founder and executive director and separately lists Donald Trump as co-founder emeritus.
Part A.12, pages 9–10, and Part D.5, pages 13–14WLF names Folkman as co-founder and executive director · Listed as WLF co-founder and executive director on November 27, 2025
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World Liberty Financial's MiCA paper lists Chase Herro as co-founder and executive director and separately lists Donald Trump as co-founder emeritus.
Part A.12, pages 9–10, and Part D.5, pages 13–14WLF names Herro as co-founder and executive director · Listed as WLF co-founder and executive director on November 27, 2025
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World Liberty Financial's November 2025 MiCA paper lists adult Barron Trump as a co-founder and Donald Trump as co-founder emeritus.
Part D.5, pages 13–14WLF paper lists adult Barron Trump as co-founder · Listed as WLF co-founder on November 27, 2025
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World Liberty Financial's November 2025 MiCA paper lists Alex Witkoff as a co-founder and Donald Trump as co-founder emeritus.
Part D.5, pages 13–14WLF regulatory paper lists Alex Witkoff as co-founder · Listed as WLF co-founder on November 27, 2025
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World Liberty Financial's November 2025 MiCA paper lists Zachary Witkoff as a co-founder and Donald Trump as co-founder emeritus.
Parts A and D, pages 9–14; publication date on page 20WLF regulatory paper lists Zach Witkoff as co-founder · Listed as WLF co-founder on November 27, 2025
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World Liberty Financial's MiCA paper says the project raised more than $550 million through token sales and lists Alex Witkoff as a co-founder.
Part A.17, pages 10–11, and Part D.5, pages 13–14WLF reports more than $550 million in token sales · Project reported more than $550 million in token sales
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The Office of the Comptroller of the Currency's public notice records World Liberty Trust Company's application for a national trust-bank charter; the proposed business included issuing and redeeming its branded stablecoin, managing stablecoin reserves, and digital-asset custody.
Part D.5 and related-party sections listing WLF co-founders, supporters, token allocations, and affiliated entitiesWorld Liberty applied for a national trust-bank charter · Application later received preliminary conditional approval
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Reuters reported that early World Liberty Financial investors could already trade 20% of their WLFI tokens and that WLF proposed keeping the remaining 80% locked for two years before vesting it over another two years; investors were due to vote the following week. The same report said WLF had borrowed $75 million against its own tokens, reported repaying $25 million on April 10, and faced investor complaints about frozen funds while WLFI reached a $0.078 low on April 12.
Part D.5 and related-party sections listing WLF co-founders, supporters, token allocations, and affiliated entitiesWLF proposed keeping 80% of early investors' tokens locked · Token-release proposal awaiting an investor vote at the report date
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Reuters reported that World Liberty Financial's 'Super Node' tier promised guaranteed access to the WLF team for investors who locked at least $5 million of WLFI; the reporting did not identify a participant or show that the offer produced access to government policy makers.
Part D.5 and related-party sections listing WLF co-founders, supporters, token allocations, and affiliated entitiesWLF set a $5 million token-lock threshold for guaranteed team access · Super Node tier reported in WLF investor materials
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Trump's certified disclosure reports that DT Marks Defi LLC received $65,625,000 in 2025 net proceeds from a sale of equity in WLF Holdco LLC.
Part D.5 and related-party sections listing WLF co-founders, supporters, token allocations, and affiliated entitiesDT Marks Defi reported $65.625 million from a WLF Holdco equity sale · Net equity-sale proceeds reported for 2025
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Trump's 2026 disclosure reports $196,875,000 in net proceeds to DT Marks SC LLC from a capital contribution by new Stablecoin Holdco LLC members and a sale of Stablecoin Holdco Class C units; DT Marks SC reported a 38.25% Stablecoin Holdco interest and ownership of 69% by DTTM Operations, 30% by Trump family members, and 1% by its managing member.
Part D.5 and related-party sections listing WLF co-founders, supporters, token allocations, and affiliated entitiesDT Marks SC reported $196.875 million from Stablecoin Holdco financing · Combined financing proceeds reported for 2025
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Trump's 2026 disclosure lists 15.75 billion World Liberty Financial governance tokens in a DTTM Operations wallet and places the holding in its over-$50-million value band; the filing reports no income on that line.
Part D.5 and related-party sections listing WLF co-founders, supporters, token allocations, and affiliated entitiesDTTM disclosed 15.75 billion WLFI governance tokens · Holding valued in disclosure at more than $50 million
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Trump's 2026 disclosure reports $8,326,828 in 2025 net operating income for the stablecoin business held by Stablecoin Holdco LLC; DT Marks SC reported a 38.25% ownership interest, while the amount distributed to that entity is unspecified.
Part D.5 and related-party sections listing WLF co-founders, supporters, token allocations, and affiliated entitiesStablecoin business reported $8.33 million in net operating income · Net operating income reported for 2025
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Trump's certified 2026 disclosure reports ten 2025 distributions from World Liberty Financial token sales to DT Marks Defi LLC totaling $526,810,321; it says DT Marks Defi held a 38.25% interest in WLF Holdco and was owned 69% by DTTM Operations, 30% by Trump family members, and 1% by its managing member.
Part D.5, co-founder and supporter listingsTrump-linked WLF entity reported $526.8 million in token-sale distributions · Distributions reported for calendar year 2025
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Trump's disclosure reports $1,821,628 in Ethereum validator rewards at DT Marks Defi LLC and $510,808 at CIC Digital LLC in 2025.
Part D.5 and related-party sections listing WLF co-founders, supporters, token allocations, and affiliated entitiesTwo Trump-linked entities reported itemized validator rewards · Validator rewards reported for 2025
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OCC Corporate Decision 1385 granted preliminary conditional approval for World Liberty Trust Company, National Association; Reuters reported the charter would let the company issue its branded stablecoin and manage reserves, while final opening remained subject to capital, governance, and other pre-opening conditions.
Part D.5 and related-party sections listing WLF co-founders, supporters, token allocations, and affiliated entitiesOCC conditionally approved World Liberty's national trust charter · Preliminary conditional approval; pre-opening conditions remain