Brian P. Brooks
Brooks exemplifies the industry-to-regulator-to-industry pivot: a crypto-industry general counsel who authored federal banking interpretive letters and then returned to the same industry, with the letters surviving across administrations to scaffold later national-bank charters and stablecoin programs.
Brian Paul Brooks (born September 1969, Pueblo, Colorado) is an American financial-services lawyer who served as Acting Comptroller of the Currency from May 29 2020 to January 14 2021, and who under that authority signed three Office of the Comptroller of the Currency interpretive letters that established the federal legal scaffolding for national-bank custody of digital assets, bank holding of stablecoin reserves, and bank participation as validator nodes on independent node verification networks 1. The three letters most associated with his tenure are Interpretive Letter #1170 (issued July 22 2020, bank crypto custody), Interpretive Letter #1172 (September 21 2020, deposits as stablecoin reserves), and Interpretive Letter #1174 (January 4 2021, validator-node participation and stablecoin payment activity) 1. On his last full day as Acting Comptroller in January 2021 the OCC granted Anchorage Digital Bank the first national-trust charter awarded to a crypto-native institution 1.
Before the OCC, Brooks held the Chief Legal Officer role at Steven Mnuchin's OneWest Bank from 2011 to 2014 and at Coinbase from September 2018 to May 2020 1. He returned to the cryptocurrency industry within months of leaving the regulator, serving briefly as chief executive of Binance.US in 2021 before being named CEO and then a continuing director of Bitfury Group Limited (UK Companies House 11441275); Companies House records pulled May 7 2026 list his appointment as a current director with effect from December 20 2021 2. On December 20 2024 Brooks was appointed to the board of directors of MicroStrategy / Strategy Inc (Nasdaq: MSTR), the bitcoin-treasury vehicle led by Michael Saylor 1.
The three Brooks-era OCC interpretive letters have outlasted his tenure and remain operative federal banking law, invoked by 2025-era OCC personnel: the October 15 2025 conditional approval of Erebor Bank, N.A. explicitly cites Interpretive Letters #1170 and #1174 as the legal scaffold for the new charter 34. On this record Brooks stands as a clear example of an industry-alumnus regulator who authored deregulatory legal artifacts that survive across administrations and are reanimated by next-cycle personnel 5.
Career and OCC Acting Comptroller Tenure
Brooks holds an A.B. from Harvard College (Government) and a J.D. from the University of Chicago Law School, and is a member of the American Law Institute 1. His pre-OCC career moved through O'Melveny & Myers (DC managing partner, financial-services chair), the Vice Chairman and Chief Legal Officer role at Steven Mnuchin's OneWest Bank from 2011 to 2014, the Executive Vice President and General Counsel role at Fannie Mae from 2014 to 2018 covering a post-conservatorship balance sheet of approximately 3.2 trillion dollars, and the Chief Legal Officer position at Coinbase from September 2018 to May 2020 1. He sold approximately 4.6 million dollars of Coinbase stock in connection with his departure for the OCC in mid-2020 1.
Brooks served as Acting Comptroller of the Currency from May 29 2020 to January 14 2021 1. During that eight-month period the OCC issued the first fintech national-bank charter (Varo, July 2020), the first national-trust charter to a crypto-native institution (Anchorage Digital Bank, January 2021), and conditional charters to SoFi, Paxos, and Protego 1. His successor, Acting Comptroller Michael Hsu, issued Interpretive Letter #1179 in November 2021 to claw back the framework through a supervisory non-objection requirement; the documentary record characterizes that measure as structurally reversible rather than a withdrawal of the underlying legal interpretations 14.
Authorship of Interpretive Letters #1170, #1172, and #1174
Three OCC interpretive letters issued during the Brooks tenure form the substantive deregulatory product of his time as Acting Comptroller 1. Interpretive Letter #1170, issued July 22 2020, concluded that national banks have authority under 12 USC 24(Seventh) to provide cryptocurrency custody services to customers 1. Interpretive Letter #1172, issued September 21 2020, concluded that national banks may hold reserves on deposit for issuers of stablecoins backed one-to-one by a single fiat currency 1. Interpretive Letter #1174, issued January 4 2021 (ten days before Brooks's departure), concluded that national banks may participate in independent node verification networks as validator nodes and may use stablecoins to facilitate payment activities 1.
Taken together, the three letters supply the federal-bank legal scaffolding for any subsequent stablecoin program or crypto-bank charter that depends on national-bank rails, including the USD1 stablecoin, the World Liberty Financial programmatic stack, and the Tahnoon-cluster digital-asset vehicles 14. The October 15 2025 OCC conditional approval letter for Erebor Bank, N.A. shows the bank's organizers explicitly invoking Interpretive Letters #1170 and #1174 (alongside the Hood/Gould-era Interpretive Letter #1184 of May 7 2025) as the legal basis for holding non-asset-backed virtual currencies on balance sheet to pay so-called gas fees under 12 USC 24(Seventh) 3.
Anchorage Digital Charter (January 2021)
On January 13 2021, one day before the end of his term, Brooks's OCC granted Anchorage Digital Bank the first national-trust charter awarded to a crypto-native institution 1. Anchorage's charter is the prototypical vehicle authorized under the Brooks-era interpretive framework, and the institution was subsequently subjected to an OCC consent order in April 2022 over anti-money-laundering deficiencies 6.
An Anchorage Digital co-founder later served as an independent director of Erebor Bank, N.A., the entity whose 2025 charter was approved against the same Brooks-era interpretive scaffolding 6. The Erebor approval letter of October 15 2025 shows the OCC imposing a Tier-1 Leverage Ratio condition of twelve percent for the bank's first three years of operation, against the standard nine-percent community-bank leverage ratio 3. That elevated capital condition reads as an attempt to ring-fence the same risk profile that produced the Anchorage 2022 consent order 6.
Post-OCC Bitfury Group Tenure
After a four-month tenure as chief executive of Binance.US in 2021, Brooks was named CEO of Bitfury Group from October 2021 through December 2022 1. Companies House records for Bitfury Group Limited (UK 11441275), retrieved May 7 2026, list Brooks as a current director with an appointment date of December 20 2021, eleven months and six days after his departure from the OCC on January 14 2021 2. The current four-person board consists of Brooks, the Latvian co-founder Valerijs Vavilovs (resident in the United Arab Emirates and the sole Person of Significant Control with seventy-five percent voting rights), the Georgian executive George Kikvadze, and the French national Bertrand Gauquelin des Pallieres (also UAE-resident) 2.
Bitfury Group Limited approved share-premium cancellations and a dividend of approximately 53.9 million dollars on December 23 2024, with a related September 30 2024 share-premium cancellation effective March 1 2024 2. The board links des Pallieres (a Partner at OneIM, the Abu Dhabi private-credit firm associated with Sheikh Tahnoon bin Zayed Al Nahyan's investment ecosystem), Brooks, and Vavilovs 7. Two of its ex-Bitfury alumni subsequently held senior positions at the OCC: Brooks in 2020 and Jonathan Gould in 2025 7.
Brian P. Brooks
Strategy Board Appointment and December 2024 Pre-Positioning
On December 20 2024, per OCC tenure records and Strategy Inc disclosures, Brooks was appointed to the board of directors of Strategy Inc (formerly MicroStrategy, Nasdaq: MSTR), the bitcoin-treasury vehicle led by Michael Saylor 1. The appointment fell thirty-four days before the SoftBank 50-million-dollar private-investment-in-public-equity transaction into Cipher Mining (the Bitfury-spinoff Nasdaq vehicle) executed via a SoftBank-affiliated Star Beacon LLC structure 1.
The August-to-December 2024 window contains a cluster of US Delaware-domiciled holding-company filings by four actors in this network: the Brooks Strategy appointment of December 20 2024; the August 2024 Delaware registration of MGX Fund Management LLC; the September 2024 New York registration of MGX; and the Black-family Fortinbras Enterprises LP Delaware filings naming Asad Hussaini and Ben Black as principals 8. Cross-referencing the filings, the coincidence of these registrations with Aryam Investment 1's January 16 2025 World Liberty Financial transaction and the January 21 2025 Stargate AI-infrastructure announcement supports reading the period as a coordinated pre-positioning window rather than an unrelated sequence of corporate events 8.
Reanimation of Brooks-Era Interpretive Letters by 2025 OCC Personnel
The Brooks-era interpretive-letter framework was reanimated by 2025 OCC personnel rather than rewritten 4. The principal documented vehicle of that reanimation is the OCC conditional approval of Erebor Bank, N.A. on October 15 2025 3. The Erebor approval letter, recorded under OCC Control Number 2025-Charter-342076 and Charter Number 25357, names Wendy Goldberg of Skadden Arps Slate Meagher Flom LLP as counsel of record, and explicitly cites Brooks-era Interpretive Letters #1170 (July 20 2020) and #1174 (January 4 2021), together with the Hood/Gould-era Interpretive Letter #1184 (May 7 2025), as the legal scaffolding for the new bank's authority to hold non-asset-backed virtual currencies on balance sheet 3.
Three documented revolving-door links connect the Erebor approval to the Brooks-era OCC 6. The Comptroller, Jonathan Gould, served as Bitfury Group Chief Legal Officer from 2022 to 2025 and as OCC Chief Counsel during the Brooks 2020 to 2021 tenure; the OCC Chief Counsel Adam Cohen (installed August 11 2025) was the Skadden partner who filed Erebor's June 11 2025 charter application; and an Anchorage Digital co-founder, whose institution holds the prototypical Brooks-era OCC crypto charter from January 2021, sits as an independent director of Erebor 6. On this evidence Brooks is a clear example of the pattern in which an industry-alumnus regulator authors deregulatory legal artifacts that survive across administrations and are reanimated by next-cycle personnel from the same firm or its industry counterparts 5.
Significance to the Investigation
The documentary record locates Brooks's significance not in the eight-month Acting Comptroller tenure itself but in the durability and reach of the three interpretive letters issued under his signature 1. The same three letters function across administrations as operative federal banking law rather than as a withdrawn or superseded framework 4. The October 15 2025 Erebor approval letter shows Interpretive Letters #1170 and #1174 remaining the controlling legal interpretations under which the OCC currently authorizes national-bank crypto-custody and validator-node activity, with the additional 2025 letter (Interpretive Letter #1184, issued May 7 2025 under the Hood/Gould OCC) extending rather than replacing the Brooks framework 3.
Two ex-Bitfury alumni have now occupied senior OCC positions across two administrations: Brooks as Acting Comptroller in 2020 to 2021 and Jonathan Gould as confirmed thirty-second Comptroller from July 10 2025, sharing the same UK private company (Bitfury Group Limited, Companies House 11441275) and the same UAE-anchored ownership structure as institutional anchor 7. Read alongside the explicit citation of Brooks-era letters in 2025-era charter approvals, that two-instance Bitfury-to-OCC pattern supports treating Brooks's regulatory output as a persistent deregulatory product rather than the policy of a single eight-month administration 5.
All Connections
5 total
All Connections
5 totalBrooks served as Vice Chairman + Chief Legal Officer at OneWest Bank (Mnuchin's bank) 2011-2014 — pre-Trump-1.0 GOP/financial-nominee provenance line.
Brooks joined MicroStrategy/Strategy (NASDAQ: MSTR) board Dec 20 2024 alongside Galaxy Digital director Jane Dietze — 34 days before SoftBank's $50M PIPE into Cipher Mining via Star Beacon LLC. Direct policy-coordination link with Saylor's bitcoin-treasury platform forming as Trump 2.0 was assembled.
Both Brian P. Brooks (2020 OCC Acting Comptroller) and Jonathan Gould (2025+ confirmed 32nd Comptroller of Currency) are ex-Bitfury executives. Two consecutive crypto-firm-alumni installed at the OCC within five years. Bitfury Group Ltd UK 11441275 is the shared institutional anchor; des Pallieres also sits on its board.
Director of Bitfury Group Ltd (UK CO# 11441275) since 20 Dec 2021. Companies House register confirms appointment 11 months after OCC departure (Jan 14 2021). Address c/o Fieldfisher LLP London.
Co-directors at Bitfury Group Limited (UK 11441275). Brooks = former US Acting Comptroller of the Currency under Trump. Anomalous board lineup (Latvian/Georgian/French + ex-US bank regulator) on a blockchain firm.
All Findings
8 total
All Findings
8 totalrelationship (2)
The Bitfury Group Ltd UK 11441275 board ties together des Pallieres (OneIM, Misra), Brooks (ex-OCC, MicroStrategy), and Vavilov, and a recurring Bitfury-to-OCC Comptroller pipeline runs through it (Brooks 2020 Acting; Jonathan Gould 2025-, ex-Bitfury exec)
Board members of Bitfury Group Ltd UK 11441275 and their wider roles: Bertrand Gauquelin des Pallieres (director and OneIM Partner, Private Credit, Abu Dhabi), Brian P. Brooks (Bitfury board ~2021-2022, ex-OCC Acting Comptroller 2020-2021, joined MicroStrategy/Strategy board Dec 20 2024), and Valery Vavilov (founder via V3 Holding Ltd -> Bitfury Group Limited UK 11441275 -> Bitfury Top HoldCo B.V., Strawinskylaan 3051 Amsterdam). The Bitfury-to-OCC pipeline appears twice: (1) Brooks in 2020 (Bitfury board to OCC Acting Comptroller, author of Interpretive Letters 1170/1172/1174, the stablecoin/crypto-bank framework that scaffolds Tahnoon-WLFI deals); (2) Jonathan Gould in 2025 (Jones Day to Bitfury exec to confirmed 32nd Comptroller Jul 10 2025, who granted Erebor what he called the first full-service national bank charter in four years). Two separate Bitfury alumni thus took the crypto-banking regulator role. des Pallieres, through whom Misra met Benedetti and who is now a OneIM Partner in Private Credit (Mubadala-anchored), sits on the same Bitfury board. On this evidence Bitfury functions as an institutional bridge between Tahnoon-cluster crypto policy and US bank-regulator personnel, independent of Epstein, which weighs against reading the Brooks appointment as coincidence and in favor of an institutional-pipeline interpretation.
A Delaware holding-company registration window in late 2024 catches four network actors (Brooks via the Strategy MSTR board appointment Dec 20 2024; Klein via the AltC SPAC family; Hussaini and Ben Black via Fortinbras Enterprises LP Delaware), a clustering that immediately precedes Misra's Nov 12 2024 SoftBank exit and OneIM's Nov 19 2024 8B upsize
Within roughly 90 days of Misra's formal SoftBank exit (Nov 12 2024) and OneIM's Nov 19 2024 8B upsize, four network actors took new positions in US Delaware holding-company architecture: (1) Aug 2024, MGX Fund Management LLC registers in Delaware (a Mubadala-affiliated UAE sovereign vehicle, also registered in NY Sept 2024 #3803). (2) Sept 2024, Leon Black opens the 'Scimitar' family office at ADGM (described as Elysium's first international office), with Ben Black and Asad Hussaini named as principals, alongside Fortinbras Enterprises LP (Delaware, a credit platform). (3) Dec 20 2024, Brian P. Brooks joins the MicroStrategy / Strategy (NASDAQ MSTR) board alongside a Galaxy Digital director; Strategy is Saylor's bitcoin-treasury vehicle, positioned for stablecoin issuance under Brooks's OCC Interpretive Letters. (4) Jan 31 2025, Trump nominates Ben Black for DFC CEO, three days after Bloomberg reported Apollo's interest in X (Twitter) debt; Apollo bought X debt at 97c in February. On the related WLFI-Aryam-MGX axis: the Aryam-WLFI agreement was signed 16 Jan 2025 (Tahnoon's UAE 49% stake in Trump-family DeFi via G42 executives), and the Stargate B AI-infrastructure JV (Trump-Son-Altman) was announced 21 Jan 2025, with Misra positioned through OneIM to intermediate. Read together, the late-2024 window indicates a coordinated pre-positioning of US regulatory and holding-company architecture by Tahnoon-Mubadala-anchored capital. Klein, though co-cited with Misra and Benedetti at Hotel Baur au Lac in Nov 2017, sits structurally adjacent (AltC SPAC, Churchill Capital, Strategy/MSTR via M. Klein & Co) rather than inside the Mubadala flow.
intelligence (3)
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'
Three documented revolving-door links converge on the Erebor approval (Oct 15 2025): (1) Gould: the Comptroller is ex-Bitfury Group CLO (2022-2025) and prior OCC Chief Counsel (Brooks tenure 2020-21), confirmed in the Warren confirmation letter and a 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 application; named as a recusal subject in the Warren Feb 2026 letter Q8-Q10. (3) Mónica: an Erebor independent director is an Anchorage Digital co-founder; Anchorage holds the prototypical Brooks-era OCC crypto charter (Jan 2021), later subject to an OCC consent order (Apr 2022, AML deficiencies), the same risk profile Erebor's 12% Tier-1 condition seeks to ring-fence. Erebor's approval letter explicitly cites Brooks-era ILs #1170 and #1174 as legal scaffold, so the framework Brooks wrote at OCC, then served under at Bitfury, is now applied by Bitfury's ex-CLO (now Comptroller) to charter a bank advised by his Chief Counsel's former 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.
Seven cross-cutting patterns observed across the network. (1) The industry-to-regulator revolving door appears in four instances: a three-instance industry-firm-to-OCC-to-implementation pipeline (Brooks 2020 Coinbase->OCC->Bitfury; Gould 2025 Bitfury/BlackRock/Promontory->OCC; Cohen 2025 Skadden->OCC->Erebor approval, with Cohen's 65-day window the tightest), alongside a parallel firm->OMB->Schaerr Jaffe->OMB pattern via Paoletta (2018 and 2025) at OMB, CFPB, and OIRA, which is structurally distinct from the OCC pipeline. (2) Brooks-era IL #1170/#1174 and IL #1184 are cited as operative law in the Erebor approval letter, with the framework now scaffolding WLFI/Tahnoon flows. (3) Aryam Investment 1, a Tahnoon vehicle, bought 49% of WLFI for $500M ($187M to Trump-family entities); G42's Edelman and Xiao were seated undisclosed; MGX deployed $2B in WLFI USD1 to Binance May 2025. (4) The 'Mubadala unifies' model extends to three SCFEA sovereign pillars (ADIA, Mubadala, and L'IMAD, ~$300B following the Jan-2026 consolidation under Khaled bin Mohamed bin Zayed), a regulatory layer (Al Shorafa as ADX, SCA, and ADGM Vice Chair), and a US-listing layer (Kazim as Nasdaq Inc. director via Borse Dubai); these bridges outlast individual principals. (5) Pre-positioning trades cluster around the Jan 2025 Stargate window: the Bitfury $53.9M dividend Dec 23 2024 (38 days before the Cipher PIPE), AltC's May 2024 close with an anomalous $7,457.80 redemption out of ~30M shares (the PIPE backstop was not triggered), Crusoe's start of Abilene construction Jun 2024 (7 months before the Stargate announcement), and SoftBank's full exit from Cipher Q3 2025, suggesting Stargate largely re-bundled preexisting infrastructure already in motion. (6) Klein-Altman-Oklo and Stargate-MGX are separate at SEC primary-source level despite merged press treatment; Altman resigned the Oklo board Apr 22 2025, three months after the Stargate announcement. (7) bin Sulayem resigned from DP World Feb 13 2026 after the DOJ Epstein release, the first observed loss for the Tahnoon network on Epstein-related exposure; his replacement Kazim maintains and extends US-market access via a Nasdaq Inc. board seat. Several identifications were corrected: Stéphane to Bertrand G. des Pallières; Antoine Bremner (unverified) to likely Christopher Bremner; Compagnie Du Saleve B223232 was incorporated 2018 and so cannot be the 28 Oct 2015 entity (likely the closed French SARL #803012046 instead); SKAS is the Saker Aviation Services ticker, not a partners' acronym; the Hoffenberg claim that Gold shielded Epstein has no docket support in 1:94-cr-00213.
Three recurring structural patterns across the network: durable deregulation scaffolding, announcement bundling, and controlled detachment
Three recurring patterns emerge from the broader record. (1) Durable deregulation scaffolding: OCC interpretive letters act as persistent legal artifacts that survive across administrations and are reanimated by counsel from the issuing firm, seen in the Brooks 2020 IL #1170/#1174 and IL #1184 cited in the 2025 Erebor approval. (2) Announcement bundling: pre-existing infrastructure is repackaged as a 'new' announcement that becomes the price-moving event, as in the Stargate cluster, the Bitfury Dec 2024 dividend (38 days before the Cipher PIPE), AltC's May 2024 anomalous redemption, Crusoe's Jun 2024 Abilene construction (7 months pre-announcement), and SoftBank's full Cipher exit Q3 2025. (3) Controlled detachment: a visible loss substitutes for, while maintaining or extending, structural capability, as when bin Sulayem stepped down Feb 13 2026 and Kazim entered the Nasdaq Inc. board via Borse Dubai, extending US-market access. Two further patterns were observed but held in reserve: narrative-filing divergence (press merging of structurally separate SEC filings, such as Stargate-MGX and Klein-Altman-Oklo) and an asset-as-compensation channel (real assets such as an Italian villa held via UK Harbour vehicles substituting for cash in opaque service relationships).
identity (2)
Brian P. Brooks authored the OCC crypto-banking framework (Interpretive Letters #1170/#1172/#1174) as Acting Comptroller; sits on the Bitfury board with des Pallieres, UAE-resident Vavilov, and Georgian Kikvadze; joined the MicroStrategy/Strategy board Dec 20 2024 (34 days before SoftBank's $50M Cipher Mining PIPE via Star Beacon)
Born Sep 1969 Pueblo Colorado; Harvard AB (Government); University of Chicago JD; American Law Institute member. Career: O'Melveny & Myers Managing Partner DC Chair Financial Services → 2011-2014 VC + Chief Legal Officer at OneWest Bank (Steven Mnuchin's bank) → 2014-2018 EVP/GC at Fannie Mae ($3.2T) → Sep 2018-May 2020 Chief Legal Officer Coinbase → May 29 2020-Jan 14 2021 Acting Comptroller of the Currency (Trump 1.0) → Apr-Aug 2021 Binance.US CEO (resigned 4mo over 'strategic differences') → Oct 2021-Dec 2022 Bitfury Group CEO → Dec 20 2021-present Bitfury board director → Mar 2023+ HBAR Foundation board → Apr 2024+ Chairman & CEO Meridian Capital Group (mortgage broker, succeeded co-founder Ralph Herzka) → Dec 20 2024+ board director Strategy Inc/MicroStrategy (NASDAQ: MSTR) alongside Galaxy Digital director Jane Dietze. The interpretive letters issued during his OCC tenure: IL #1170 (Jul 22 2020) bank crypto custody; IL #1172 (Sep 21 2020) bank deposits as stablecoin reserves; IL #1174 (Jan 4 2021) banks as validator nodes + stablecoin payments; first crypto national-trust charter (Anchorage Digital Bank Jan 2021); first fintech national bank charter (Varo Jul 2020); conditional charters for SoFi, Paxos, Protego. Acting Comptroller Hsu's IL #1179 (Nov 2021) sought to claw these back via supervisory non-objection, a structurally reversible measure rather than a withdrawal of the underlying interpretations. The three letters supply the legal scaffolding for any program seeking national-bank crypto rails, including WLFI/USD1 stablecoin, Tahnoon-DTR/DRAM, and MGX-Stargate. Subsequent Trump-administration activity: met Trump in person Nov 2024; traded as a 40% lead candidate on Kalshi for SEC Chair (Atkins ultimately selected); considered for a proposed White House Crypto Advisor role. The OneWest Mnuchin connection predates the first Trump administration. Sold $4.6M of Coinbase stock when leaving for OCC June 2020. Brooks's MSTR appointment (Dec 20 2024) came 34 days before SoftBank's $50M PIPE into Cipher Mining (Bitfury's NASDAQ spinoff). His concurrent board seats span MSTR (Saylor bitcoin treasury), HBAR (smart-contract layer-1), Bitfury (mining infrastructure), and Meridian (mortgage broker).
Bitfury Group Ltd UK CO# 11441275 — verified board roster + 4 documented departures 2018-2024 + 2024 $53.9M share-premium cancellation
Companies House register (pulled May 7 2026) for 11441275: CURRENT (4): Brian Paul BROOKS (American, USA-resident, appointed 20 Dec 2021 — 11 months after his OCC departure Jan 14 2021); George KIKVADZE (Georgian); Bertrand Gauquelin Des PALLIERES (French, UAE-resident; address 'Centricus, Byron House, 7-9 St James's Street'); Valerijs VAVILOVS (Latvian, UAE-resident; Dubai address Cheddar Cheese Tower O-14, Marasi Drive, Business Bay). FORMER (4): Antoine Jacques DRESCH (resigned 25 Jan 2024 — 11 months before SoftBank-Cipher Star Beacon PIPE); Robert Roscoe Bernard DYKES (American, resigned 31 Aug 2020 — three weeks after Brooks's elevation to Acting Comptroller May 2020 + ~3 weeks after IL #1170 was issued July 22 2020); Jeremy Paul SEWELL (in/out same month Jul 2018, 1 Angel Court — incorporation agent); William Ping TAI (American, resigned 1 Sep 2020 — same week as Dykes). Sole PSC: Vavilovs — >25%-50% shares, 75%+ voting rights, right to appoint/remove. Identity verification due 12 Jul 2026. Key filings: 23 Dec 2024 RESOLUTIONS $53.9M share-premium cancellation & dividend; 30 Sep 2024 RESOLUTIONS share-premium cancellation effective 1 Mar 2024. Two equity returns to Vavilovs in 2024 worth tens of millions. SH01 share allotments 5 Sep 2025, 21 Jan 2026, and 19/16/15 Feb 2024 indicate the capital structure was being actively restructured. A filing dated 4 Aug 2025 retroactively backdated des Pallieres's appointment details to 1 Feb 2023.
document (1)
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.