Adam J. Cohen
Cohen is the legal hinge between the private bar and federal banking regulation: the same attorney who drafted and submitted a national-bank charter application became, within sixty-one days, the OCC official whose office reviewed it. The case demonstrates how a single revolving-door transition can compress what is normally a multi-year, arms-length regulatory process into a four-month internal review.
Adam J. Cohen is a U.S. financial-regulatory attorney who served as Co-Head of Skadden, Arps, Slate, Meagher & Flom LLP's Financial Institutions Regulatory Group from May 2024 until his appointment as Senior Deputy Comptroller and Chief Counsel of the Office of the Comptroller of the Currency (OCC) effective August 11, 2025. 1 Cohen previously served as General Counsel of SoFi and held earlier positions at the Federal Reserve Board and the Commodity Futures Trading Commission. 1
On June 11, 2025, Cohen filed the national-bank charter application for Erebor Bank, N.A. as Skadden counsel; the OCC announced his appointment as Chief Counsel sixty-one days later via press release nr-occ-2025-76 dated July 30, 2025. 1 The OCC granted Erebor preliminary conditional approval on October 15, 2025, sixty-five days into Cohen's OCC tenure; the approval letter was addressed to Wendy M. Goldberg of Skadden's One Manhattan West office, Cohen's former colleague at the same firm. 1 Erebor's principal backers, per Senate Banking Committee correspondence, include Palmer Luckey, Joe Lonsdale, and Peter Thiel. 1
On February 25, 2026, Senator Elizabeth Warren issued a letter to Comptroller Jonathan V. Gould demanding documentation of Cohen's recusal and asking, in the letter's own language, whether the OCC's process "may have been contaminated by backroom political manipulation" amounting to "a corrupt political favor to the President's billionaire supporters in Silicon Valley." 1 Warren letter Questions 8-10 specifically ask whether Gould "discussed Erebor's application with Mr. Cohen either before or after he joined the OCC" and whether Gould was "aware he served as counsel to Erebor and submitted the company's charter application" when hired. 1 As of this dossier's last update, Cohen's recusal documentation has not been publicly disclosed. 1
The Skadden-OCC Timeline
The Skadden-to-OCC sequence is documented to the day in the Senate Banking Committee correspondence and the OCC's own public records. Cohen joined Skadden in May 2024 as Co-Head of the Financial Institutions Regulatory Group alongside Mark Chorazak. 1 On June 11, 2025, while still a Skadden partner, Cohen filed the de novo national-bank charter application for Erebor Bank, N.A. on behalf of organizers including Palmer Luckey, Joe Lonsdale, and Peter Thiel. 1
The OCC announced Cohen's appointment as Senior Deputy Comptroller and Chief Counsel via press release nr-occ-2025-76 on July 30, 2025, with an effective date of August 11, 2025. 1 The interval between charter filing and OCC appointment is sixty-one days. The OCC issued preliminary conditional approval of the Erebor charter on October 15, 2025, sixty-five days into Cohen's tenure as Chief Counsel, with the approval letter addressed to Wendy M. Goldberg of Skadden, Arps, Slate, Meagher & Flom LLP. 1
According to the OCC approval letter cited in the Senate Banking correspondence, the legal scaffold for Erebor's authority to hold non-asset-backed virtual currencies on balance sheet rests on three OCC Interpretive Letters: #1170 (July 20, 2020) and #1174 (January 4, 2021), both issued during Brian Brooks's tenure as Acting Comptroller, together with IL #1184 (May 7, 2025). 1 Per the same Senate correspondence, the bank received its preliminary conditional approval within roughly four months of application — a compressed timeline relative to the typical multi-year vetting cycle for de novo national banks. 1
The Warren Letter and Recusal Questions
Senator Elizabeth Warren's February 25, 2026 letter to Comptroller Jonathan V. Gould is the principal public document raising procedural questions about Cohen's role. 1 The letter establishes the application-to-appointment timeline and demands that the OCC produce Cohen's recusal documentation. 1 Questions 8 through 10 specifically ask whether Gould "discussed Erebor's application with Mr. Cohen either before or after he joined the OCC" and whether Gould "was aware he served as counsel to Erebor and submitted the company's charter application" at the time of Cohen's hiring. 1
According to Warren's letter, the underlying concern is whether the OCC's process "may have been contaminated by backroom political manipulation" — described in the letter as potentially "a corrupt political favor to the President's billionaire supporters in Silicon Valley." 1 These are direct quotations from Warren's letter and are presented here with attribution; the language reflects the Senator's framing rather than an independent finding by this investigation.
Analysis of Finding #11184 indicates that if Cohen's recusal from the Erebor matter was untimely or absent, the resulting charter could be procedurally voidable under federal conflict-of-interest standards. 1 This is an inference drawn from the timeline and the questions Warren has posed; it is not a confirmed legal conclusion and depends on documents the OCC has not yet released. 1
Key Relationships
Cohen's two strongest documented relationships in the investigation database are his employment at Skadden and his advisory role on the Erebor Bank charter application. Connection #5982Connection #5988 He joined Skadden in May 2024 as Co-Head of the Financial Institutions Regulatory Group and remained partner there until his August 11, 2025 OCC appointment. 1 According to Senate Banking correspondence, Erebor's counsel of record at approval, Wendy M. Goldberg, is also a Skadden attorney; the firm therefore appeared on both sides of the regulatory transom — as applicant counsel and, through Cohen, as the OCC official responsible for the office reviewing the application. 1
The Erebor board roster places Cohen one degree away from several figures already covered in this investigation. Per the OCC approval letter referenced in Warren's letter, independent director Diogo Mónica is co-founder of Anchorage Digital, which holds the OCC's first national crypto-bank charter (granted January 13, 2021, on Brian Brooks's last day as Acting Comptroller) and was later the subject of an April 2022 OCC consent order for AML deficiencies. 1 Director and principal shareholder Palmer Luckey is the founder of Anduril Industries; co-investors named in Senate correspondence include Peter Thiel and Joe Lonsdale. 1
According to Round 6 synthesis #11204, the Cohen-Skadden-OCC sequence is the third documented link in a three-instance Skadden-or-equivalent-firm-to-OCC-to-implementation revolving door, alongside Brian Brooks (Coinbase to OCC Acting Comptroller in 2020) and Comptroller Jonathan V. Gould (Bitfury and BlackRock to OCC Comptroller in 2025). 2 According to Round 6 synthesis #11236, a separate but parallel vault-firm-to-regulator-to-implementation pattern at the Office of Management and Budget — distinct from the OCC pipeline — runs through Mark Paoletta (private practice to OMB General Counsel in Trump I, then Schaerr Jaffe LLP, then back to OMB and concurrent Consumer Financial Protection Bureau and Office of Information and Regulatory Affairs roles in Trump II). 3 According to the same Round 6 synthesis #11204, Cohen's case is the tightest of the OCC-pipeline instances on a days-to-conflict basis, given that the interval from Erebor charter filing to OCC appointment to charter approval was sixty-one days plus sixty-five days 2. Cross-reference of Round 6 findings indicates this characterization is an analytical synthesis presented with attribution rather than a documented finding by an external authority 2.
Adam J. Cohen
Career History
Cohen's pre-Skadden career, as documented in Senate Banking correspondence and the OCC press release announcing his appointment, includes service as General Counsel of the consumer-finance company SoFi and earlier positions at the Federal Reserve Board and the Commodity Futures Trading Commission. 1 He joined Skadden in May 2024 alongside Mark Chorazak as Co-Head of the firm's Financial Institutions Regulatory Group. 1
The OCC press release (nr-occ-2025-76, July 30, 2025) announced Cohen's appointment as Senior Deputy Comptroller and Chief Counsel effective August 11, 2025. 1 The Chief Counsel position is the OCC's senior in-house legal role and oversees the office that reviews national-bank charter applications, including the de novo charter Cohen had filed for Erebor sixty-one days earlier as a Skadden partner. 1 Public records consulted in this investigation do not include Cohen's recusal memorandum, ethics agreement, or any statement from the OCC Inspector General regarding his handling of the Erebor matter; production of those documents is among the items demanded in Senator Warren's February 25, 2026 letter. 1
Structural Context: Brooks-Era Interpretive Letters as Live Law
The Erebor approval letter Cohen's office reviewed cites OCC Interpretive Letters #1170 (July 20, 2020), #1174 (January 4, 2021), and #1184 (May 7, 2025) as the legal framework permitting a national bank to hold non-asset-backed virtual currencies on balance sheet to pay "gas fees" under 12 U.S.C. § 24 (Seventh). 1 According to a Round 6 analytical synthesis of this investigation, the same Brooks-era interpretive-letter framework appears in the OCC posture toward stablecoin and tokenization activity associated with World Liberty Financial and the Tahnoon-vehicle Aryam Investment 1's acquisition of a 49% WLFI stake. 1 This is an analytical synthesis assertion presented with attribution; readers should treat the cross-pollination claim as investigative inference, not as a finding adjudicated by an external authority.
Per the same synthesis, the structural significance of Cohen's role is that the legal scaffold authored under Brian Brooks at the OCC, then carried into private practice and corporate-counsel posts, has now returned to the OCC as the live framework applied by personnel — including Cohen and Comptroller Gould — drawn from the firms and companies that benefit from it. 1 This characterization is drawn from the Round 6 analytical synthesis and is presented as such rather than as an independent verified conclusion. 1
All Connections
2 total
All Connections
2 totalCohen filed Erebor's June 11 2025 charter app as Skadden partner; named OCC Chief Counsel Aug 11 2025 (61 days later); OCC granted charter Oct 15 2025. Warren Feb 2026 letter demands recusal docs.
Co-Head Financial Institutions Regulatory Group from May 2024 until Aug 11 2025 OCC appointment.
All Findings
1 total
All Findings
1 totalintelligence (2)
SYNTHESIS: Erebor charter is the structural payoff of the Bitfury->OCC pipeline — three-link revolving door (Cohen/Skadden, Mónica/Anchorage, Gould/Bitfury) operating same Brooks-era IL framework; Warren letter Feb 2026 frames it as 'corrupt political favor'
Round-6 synthesis. Three documented revolving-door links converge on Erebor approval (Oct 15 2025): (1) GOULD: Comptroller is ex-Bitfury Group CLO (2022-2025) and prior OCC Chief Counsel (Brooks tenure 2020-21) — confirmed in Warren confirmation letter and Bitfury 2022 press release. (2) COHEN: OCC Chief Counsel since Aug 11 2025 was the Skadden partner who filed Erebor's June 11 2025 charter app; named recusal subject in Warren Feb 2026 letter Q8-Q10. (3) MÓNICA: Erebor independent director is Anchorage Digital co-founder; Anchorage holds the prototypical Brooks-era OCC crypto charter (Jan 2021), later subject to OCC consent order (Apr 2022, AML deficiencies — exact same risk profile Erebor's 12% Tier-1 condition tries to ring-fence). Erebor's approval letter explicitly cites Brooks-era ILs #1170 and #1174 as legal scaffold — meaning the framework Brooks wrote at OCC, then served at Bitfury, is now used by Bitfury's ex-CLO (now Comptroller) to charter a bank advised by his Chief Counsel's old law firm. Warren Feb 2026 letter frames as: 'whether the OCC's process was contaminated by backroom political manipulation... a corrupt political favor to the President's billionaire supporters in Silicon Valley.' Cited Business Insider Aug 8 2025 fundraising memo: Luckey's 'political network will get this done' and a co-founder had 'unique connectivity to banking regulators,' including Comptroller Gould. Bank approval expected by end of 2025 in fundraising memo — granted within 4 months of application (vs typical multi-year vetting for de novo banks). 'Erebor would serve as the financial hub for an interrelated set of Silicon Valley firms' — Anduril (Luckey weapons), Palantir (Thiel/Lonsdale surveillance), and a 'concentrated set' of crypto/AI/defense companies. Bank opened Feb 8 2026 without a Chief Risk Officer (Rosenberg listed in approval letter; Warren Q12 confirms departure before opening). The Bitfury->OCC pipeline is now Bitfury->OCC->Bitfury-friendly-charter pipeline, with Skadden as the legal hinge.
META-SYNTHESIS: Seven cross-lens patterns from Round 6 (Agents A-G). (1) Vault-firm regulatory revolving door is a 4-instance pattern: a 3-instance Skadden-or-equivalent->OCC->implementation pipeline (Brooks 2020 Coinbase->OCC->Bitfury; Gould 2025 Bitfury/BlackRock/Promontory->OCC; Cohen 2025 Skadden->OCC->Erebor approval — Cohen's 65-day window the tightest), plus a parallel vault-firm->OMB->Schaerr Jaffe->OMB pattern via Paoletta (2018+2025) at OMB+CFPB+OIRA — STRUCTURALLY DISTINCT from the OCC pipeline. (2) Brooks-era IL #1170/#1174 + IL #1184 are LIVE OPERATIVE LAW cited in Erebor approval letter — the deregulation framework now scaffolds WLFI/Tahnoon flows. (3) Aryam Investment 1 = Tahnoon vehicle bought 49% WLFI for $500M ($187M to Trump-family entities); G42 Edelman + Xiao seated undisclosed; MGX deployed $2B WLFI USD1 -> Binance May 2025. (4) Round 5 'Mubadala unifies' model UPGRADED to three SCFEA sovereign pillars (ADIA + Mubadala + L'IMAD ~$300B post Jan-2026 consolidation under Khaled bin Mohamed bin Zayed) + regulatory layer (Al Shorafa = ADX + SCA + ADGM Vice Chair) + US-listing layer (Kazim = Nasdaq Inc. director via Borse Dubai). Bridges outlast principals. (5) Pre-positioning trades cluster around Jan 2025 Stargate window: Bitfury $53.9M dividend Dec 23 2024 (38d before Cipher PIPE), AltC closed May 2024 with anomalous $7,457.80 redemption out of ~30M shares (PIPE backstop not triggered), Crusoe started Abilene construction Jun 2024 (7mo before Stargate announcement), SoftBank fully exited Cipher Q3 2025 — Stargate is largely re-bundling of preexisting infrastructure already in motion. (6) Klein-Altman-Oklo and Stargate-MGX are STRUCTURALLY SEPARATE per SEC primary-source level — press treatment merged them. Altman resigned Oklo board Apr 22 2025, 3 months after Stargate announce. (7) bin Sulayem resigned DP World Feb 13 2026 after DOJ Epstein release — first observed VISIBLE LOSS for Tahnoon network on Epstein-related exposure; replacement Kazim maintains/extends US-market access via Nasdaq Inc. board seat. ROUND 5 NAME CORRECTIONS: Stéphane->Bertrand G. des Pallières; Antoine Bremner unverified->likely Christopher Bremner; Compagnie Du Saleve B223232 incorporated 2018 so cannot be 28 Oct 2015 entity (likely closed French SARL #803012046 instead); SKAS = Saker Aviation Services ticker not partners' acronym; Hoffenberg 'Gold shielded Epstein' claim has NO docket support in 1:94-cr-00213.
identity (2)
Erebor organizers, directors, officers — full roster from OCC approval letter Oct 15 2025
OCC approval letter names: Owen Rapaport (Organizer/CEO/Director/Principal Shareholder; ex-Aer Compliance CEO acquired by StarCompliance); Jacob E. Hirshman (Organizer/CSO/Director/Principal Shareholder; ex-Circle); Michael Hagedorn (Organizer/President/Director); Richard E. Grant (Organizer/CFO); Trevor Capozza (Organizer/Independent Director); Palmer Luckey (Director/Principal Shareholder; Anduril founder); Diogo Mónica (Independent Director; Anchorage Digital co-founder, Haun Ventures GP); Michael Mosier (Independent Director; ex-FinCEN Acting Director); Vlad Dubinsky (Chief Credit Officer); Joshua Rosenberg (Chief Risk Officer — per Warren letter departed before bank opened); Aaron Pelz (CTO). Residency waivers under 12 USC 72 for Capozza, Hagedorn, Hirshman, Luckey, Mosier, Rapaport. Backers per Warren: Luckey, Lonsdale, Thiel — all major Trump/Vance donors. CRITICAL OVERLAP: Diogo Mónica co-founded Anchorage Digital, the OCC's first crypto bank charter (Brooks era 2021); Mosier is ex-FinCEN; structurally, Erebor's 'independence' rests on directors who built/regulated the framework now being applied to them.
Adam Cohen — Skadden partner who filed Erebor charter application appointed OCC Chief Counsel 61 days later
Sen. Warren's Feb 25 2026 letter establishes the timeline: Erebor's charter application was submitted by Adam J. Cohen, a Skadden partner, on June 11, 2025. OCC press release nr-occ-2025-76 (July 30, 2025) announced Cohen's appointment as Senior Deputy Comptroller and Chief Counsel effective August 11, 2025 — 61 days after Erebor application. Cohen co-headed Skadden's Financial Institutions Regulatory Group (joined Skadden May 2024). Prior: SoFi General Counsel; Federal Reserve Board; CFTC. Warren letter Q8-Q10 demands Cohen's recusal documentation and asks whether Gould 'discussed Erebor's application with Mr. Cohen either before or after he joined the OCC' and whether Gould 'was aware he served as counsel to Erebor and submitted the company's charter application' when hired. The Erebor charter was approved Oct 15, 2025 — Cohen had been OCC Chief Counsel for 65 days at approval. The OCC approval letter was signed to 'Wendy M. Goldberg, Counsel, Skadden, Arps' — Cohen's former colleague at the same firm.
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OCC Conditional Approval — Erebor Bank N.A. — full charter Oct 15 2025 (Skadden filed, Gould era)
OCC granted preliminary conditional approval Oct 15 2025 (OCC Control 2025-Charter-342076; Charter 25357; Residency Waivers 2025-Waiver-342510). Counsel of record: Wendy M. Goldberg, Skadden Arps Slate Meagher Flom LLP, One Manhattan West, NY. Organizing entity: Erebor Group Inc (Delaware) merges into the bank under 12 USC 215a-3. Existing subsidiary Atticus Digital Inc becomes wholly-owned post-merger. Tier-1 Leverage Ratio condition: 12% for first three years (vs 9% standard CBLR). Bank explicitly cites Brooks-era Interpretive Letters #1170 (Jul 20 2020 — written under Brooks), #1174 (Jan 4 2021 — Brooks's last day), and Hood/Gould-era IL #1184 (May 7 2025) as legal scaffold for holding non-asset-backed virtual currencies on balance sheet to pay 'gas fees' under 12 USC 24(Seventh). Confirms the Brooks-Gould interpretive-letter framework is the live operative legal scaffold for new crypto-bank charters.
- 1.Finding #11184
- 2.Finding #11204Sources: https://occ.gov/news-issuances/news-releases/2025/nr-occ-2025-101a.pdfOpen artifactSource record, https://www.banking.senate.gov/imo/media/doc/2026.02.25%20Letter%20to%20OCC%20re%20Erebor%20Approval.pdfOpen artifactSource record, https://www.businesswire.com/news/home/20220209006230/en/Bitfury-Group-Appoints-Former-OCC-Senior-Deputy-Comptroller-and-Chief-Counsel-Jonathan-Gould-Chief-Legal-OfficerOpen artifactSource record
- 3.Finding #11236