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Critics of the president’s decision to auction off a private dinner via his Trump-branded crypto token were worried about the stunt for a few reasons. At the top of the list: the potential for foreigners to buy access to the sitting president, something the US Constitution explicitly prohibits. Those concerns, it seems, were well founded. The vast majority of the top holders of Trump’s memecoin appear to be based overseas, including the top investor — a Chinese-born crypto mogul who, until recently, was facing civil fraud charges in the United States. Billed by organizers as the “most EXCLUSIVE INVITATION in the world,” Thursday’s gala is set to take place at the president’s private Trump National Golf Club, just outside of Washington, DC, according to an email sent to guests and reviewed by Fortune. The guests are expected to include President Donald Trump himself and 220 of the top $TRUMP buyers, who collectively dumped an estimated $148 million over three weeks into the memecoin — a type of crypto product that is functionally useless as a currency or investment vehicle, and one that serious investors avoid because of their tendency to collapse in value. The top 25 $TRUMP coin holders are eligible for a private White House tour the following day — the kind of access typically reserved for heads of state. And because crypto is anonymous by design, the identities of the top investors — who appeared on a public leaderboard with nothing but self-selected three- or four-letter usernames and long, cryptographic digital wallet addresses — aren’t easy to pin down. But an analysis by Bloomberg News found that all but six of the top 25 holders of the $TRUMP memecoin used foreign exchanges that are ostensibly off-limits to anyone living in the US. More than half of the top 220 holders used similar offshore exchanges, Bloomberg found. Thursday’s “ultra-exclusive private VIP reception” is just the latest instance of the Trump administration flouting ethical boundaries between the office and the president’s personal profit-seeking. His apparent contempt for such boundaries has angered commentators across the political spectrum. Sen. Chris Murphy, a Connecticut Democrat who introduced legislation to ban officials from selling memecoins, said in a hearing this week that the gala “represents a real problem” because there is “clearly a way around the State Department for foreign individuals of significant influence and wealth to be able to directly lobby the president.” And even Republican crypto advocate Sen. Cynthia Lummis of Wyoming said the event gives her “pause.” The progressive advocacy group Public Citizen is organizing a protest outside the Potomac Falls, Virginia, golf course on Thursday, and is calling on the Department of Justice and other officials to hold Trump accountable. “He’d help himself by calling off his Thursday gala,” the Wall Street Journal’s conservative editorial page wrote Tuesday. “If he won’t do that, he could at least disclose his crypto contest’s winners so Americans know who may be trying to buy access to the President.” That, too, seems unlikely. When CNN asked the White House whether a gala guest list would be released, a spokesperson replied with a statement saying: “President Trump only acts in the best interests of the American public — which is why they overwhelmingly re-elected him to this office, despite years of lies and false accusations against him and his businesses from the fake news media.” Organizers of the auction didn’t respond to CNN’s request for comment. One publicly known guest is Justin Sun, the Chinese-born crypto entrepreneur, who wasn’t exactly hiding his status. Observers were pretty sure the billionaire was leading the pack when the auction’s public leaderboard displayed the username SUN topping the ranks. Sun later confirmed on social media Tuesday that he was “honored” to support Trump and excited to attend the gala “as his TOP fan!” Trump’s reelection and his newfound enthusiasm for crypto came at a fortunate time for Sun, the 34-year-old founder of blockchain company Tron. In 2023, US regulators charged Sun and his company with selling unregistered securities and fraudulently manipulating the price of the digital token Tronix. Sun, a citizen of St. Kitts and Nevis, became the first prominent investor to back the Trump family crypto project, World Liberty Financial, which launched in the fall of 2024. Sun eventually poured at least $75 million into the World Liberty token (which is separate from the $TRUMP token), and he’s amassed more than $22 million worth of President Trump’s memecoin, based on Wednesday’s prices. All told, Sun’s actions, including the buying they sparked from other crypto enthusiasts, have generated an estimated $400 million windfall for the Trump family, according to Forbes. Then, about a month into Trump’s second term, the Securities and Exchange Commission did a 180 on virtually all of its crypto enforcement actions, including the civil fraud charges it had filed against Sun and his company. In February, SEC lawyers asked a federal judge to put the agency’s civil fraud case on hold, citing “the public’s interest.” Sun is a polarizing figure, even within crypto. He’s known as a showman, having previously spent $4.6 million on a dinner with Warren Buffett (which Sun canceled and rescheduled) and $28 million to join Jeff Bezos aboard Blue Origin’s first crewed mission (though Sun had to drop out). Sun, who told Forbes his net worth from his expansive crypto empire is over $40 billion, made headlines last year when he bought a $6.2 million conceptual artwork of a banana duct-taped to a wall. He promptly ate the banana.
