CIC Digital LLC
CIC Digital LLC is the Trump Organization entity that holds the dominant insider allocation in the TRUMP meme coin, launched three days before the January 2025 presidential inauguration. The entity earns ongoing trading fees from every secondary transaction and initially controlled 80% of token supply alongside Fight Fight Fight LLC. Several foreign nationals and entities that purchased TRUMP tokens subsequently saw favorable regulatory outcomes, though no formal investigation has established a causal link. No existing federal disclosure or divestiture framework applies to a sitting president's ownership of a commercially issued digital asset.
CIC Digital LLC is a Delaware limited liability company wholly owned by The Donald J. Trump Revocable Trust. It co-owns Fight Fight Fight LLC — the issuer of the TRUMP meme coin — with Celebration Cards LLC (Wyoming). At launch on January 17, 2025, three days before the presidential inauguration, the two entities collectively held 800 million of 1 billion tokens (80% of supply) and receive ongoing revenue from all TRUMP token trading fees. 1, 2
CIC Digital operates in parallel with DT Marks DEFI LLC, the Trump family vehicle for the separate World Liberty Financial venture. By May 2025, the Trump family had earned over $320 million in aggregate TRUMP token trading fees. 3
Entity Structure and Ownership
Trump's 2024 personal financial disclosure lists CIC Digital LLC as wholly owned by The Donald J. Trump Revocable Trust. 4 The entity jointly owns Fight Fight Fight LLC alongside Celebration Cards LLC, a Wyoming entity registered through Cloud Peak Law LLC in Sheridan, Wyoming — a registered agent known for anonymous LLC formation. 4 Bill Zanker is identified as the authorized person on Fight Fight Fight LLC's Delaware filing and leads day-to-day operations; he conceived Trump's NFT and crypto ventures and organized the May 2025 top-holder dinner. 4
Fight Fight Fight LLC is the formal token issuer. 1 Its name references Trump's reaction after the July 2024 assassination attempt. The ownership chain means that trading-fee revenue flows upward from Fight Fight Fight LLC to CIC Digital LLC and Celebration Cards LLC, and from CIC Digital to the Trump Revocable Trust. 1 The Canary Capital S-1/A (SEC Registration 333-289857, filed February 13, 2026) is the most complete primary-source description of this structure, describing CIC Digital as "an affiliate of President Trump" and detailing all six insider wallet groups with their staggered unlock schedules. 1
CIC Digital operates alongside but structurally separate from DT Marks DEFI LLC, the Trump family vehicle holding 60% equity in World Liberty Financial and its USD1 stablecoin. The two entities share a beneficial owner — Donald Trump — and collectively represent parallel commercial crypto positions held by a sitting president. 1, Connection #2471
Token Launch and Insider Allocation
The TRUMP token launched on January 17, 2025 — three days before the presidential inauguration. Within 48 hours the token reached an approximate market capitalization of $73 billion before declining sharply. The MELANIA token launched on January 18, further diluting TRUMP holders. 5
At launch, CIC Digital LLC and Fight Fight Fight LLC collectively held 800 million of the 1 billion total tokens (80%). 1 The insider allocation is divided across six wallet groups with staggered three-month unlock cliffs and 24-month linear vesting: Group 1 (36% of supply) carries a three-month cliff from launch with a first unlock date of April 18, 2025; Group 2 (18%) at six months; Group 3 (18%) at 12 months. As of February 11, 2026, approximately 53% of the total supply had unlocked and the market capitalization stood at $1.68 billion at a price of $3.14. 1
The token runs on the Solana blockchain via the Meteora liquidity pool. 1 Initial liquidity consisted of 200 million tokens (20% of supply) paired with SOL. 1 All transaction fees from TRUMP trading flow to CIC Digital LLC and Celebration Cards LLC as owners of Fight Fight Fight LLC — the fee structure is permanent and is not subject to the unlock schedule that governs the token allocation. The token launched three days before the incoming administration assumed the regulatory authority that governs cryptocurrency oversight. 5
Gala Dinner and Foreign National Holders
On May 22, 2025, President Trump hosted a black-tie dinner at his Virginia golf club for the top 220 TRUMP token holders, who had collectively spent approximately $148 million to qualify. Bloomberg analysis of the top 25 wallet holders estimated that 19 were likely foreign nationals. 3
The largest single holder at the dinner was Justin Sun, founder of the Tron blockchain, who faced an active SEC fraud case at the time. The SEC paused Sun's case on February 27, 2025, citing "public interest" — one of 10 cryptocurrency enforcement actions closed in the 70-day window from inauguration to March 27, 2025. Connection #2192 Sun had separately invested $75 million in World Liberty Financial tokens and attended the May 22 dinner as the top TRUMP holder. Connection #2192
GD Culture Group, a Nasdaq-listed company with eight employees, zero revenue, and a business model dependent on TikTok, announced a $300 million plan to purchase Bitcoin and TRUMP tokens. The $300 million was funded through a stock sale to an unnamed British Virgin Islands entity. 6 The timing correlated with Trump's signaling of a TikTok ban delay. 6 The BVI funding source for the GD Culture purchase has not been publicly identified.
Representatives Sean Casten and Christopher Smith formally demanded a DOJ investigation, citing potential violations of federal bribery statutes and the foreign emoluments clause. Thirty-five House Democrats co-signed. Cryptocurrency industry lobbyists also expressed concern that the gala dinner was jeopardizing passage of the GENIUS Act stablecoin legislation. By the day following the dinner, the TRUMP token price had declined 16%. 3
By the time of the gala, the Trump family had earned over $320 million in aggregate trading fees since launch. Approximately 764,000 retail wallets of small-denomination holders had lost money on their TRUMP token positions. 3
Regulatory Environment
On inauguration day, January 20, 2025, the SEC dropped its case against Nova Labs — the first of 10 cryptocurrency enforcement actions closed in the subsequent 70 days. On January 23, the SEC announced its Crypto Task Force; February 21, cases against Robinhood, OpenSea, Uniswap, and Crypto.com were closed; February 27, the Coinbase case was dismissed and Justin Sun's case was paused; March 27, cases against Kraken, ConsenSys, Cumberland, and Gemini were dropped. All closures occurred before new SEC Chair Paul Atkins was sworn in on April 21, 2025.
Jay Clayton, Trump's first-term SEC Chair (2017–2020), was installed as U.S. Attorney for the Southern District of New York in April 2025. Clayton's post-government financial disclosure, filed under the name "Walter Joseph Clayton," documented holdings in Fireblocks, Coinbase Asset Management, and Electric Capital Partners — digital asset firms — alongside his Apollo Global Management chairmanship and Sullivan & Cromwell senior policy advisor role. According to that disclosure, Clayton held the federal prosecutor's office with primary jurisdiction over securities fraud while maintaining positions in digital asset firms he had overseen as SEC Chair.
No federal disclosure framework required Trump to divest CIC Digital LLC upon taking office. Presidential conflict-of-interest statutes (18 U.S.C. § 208) do not apply to the President or Vice President. The Office of Government Ethics rules governing blind trusts apply to executive branch employees, not to the President. The structure thus operates in a legal gap where the largest single holder of a commercially issued digital asset is the President of the United States, with no mandatory divestiture, blind trust requirement, or trading restriction.
All Connections
4 total
All Connections
4 totalJustin Sun became the top TRUMP meme coin holder and attended the May 22, 2025 gala dinner with Trump. The SEC paused Sun's fraud charges at around the same time, citing public interest, and Sun separately invested heavily in WLFI tokens. The concurrence of his token purchases with the pause in his enforcement case has drawn scrutiny, though no causal link has been established.
Trump wholly owns CIC Digital LLC through The Donald J. Trump Revocable Trust. CIC Digital holds 36% of TRUMP token supply and receives trading fee revenue.
CIC Digital LLC co-owns Fight Fight Fight LLC alongside Celebration Cards LLC. Fight Fight Fight is the issuer of the TRUMP meme coin.
Both entities are Trump family-owned components of the family's crypto holdings. DT Marks DEFI owns 60% of WLFI; CIC Digital holds 80% of TRUMP tokens (with Fight Fight Fight LLC). They share a beneficial owner (the Trump family) and operate parallel crypto ventures under different entity structures.
All Findings
5 total
All Findings
5 totalfinancial (4)
The TRUMP token launched January 17, 2025 — three days before the inauguration on January 20. It reached a market capitalization of roughly $73 billion within 48 hours before declining sharply. The MELANIA token launched January 18, further diluting TRUMP holders. At launch, CIC Digital LLC and Fight Fight Fight LLC held 800M of 1B tokens (80%). Per the Canary TRUMP Coin ETF S-1/A (SEC Registration 333-289857), Fight Fight Fight LLC is owned by CIC Digital LLC and Celebration Cards LLC. The six insider wallet groups carry staggered three-month unlock schedules, with the first unlock April 18, 2025. All trading fees flow to CIC Digital and Celebration Cards. The launch preceded the date on which the incoming administration assumed regulatory authority over cryptocurrency oversight.
From the Canary Capital Group S-1/A filed February 13, 2026: Token Creator Affiliates (CIC Digital and Celebration Cards) initially owned 800M tokens (80%) and receive transaction fees. The six insider wallet groups have distinct unlock schedules starting three months post-launch. The token runs on the Solana blockchain via the Meteora liquidity pool, with initial liquidity of 200M tokens (20%) paired with SOL. Multiple SEC filings describe CIC Digital LLC as 'an affiliate of President Trump.' Fight Fight Fight LLC was formed specifically for this token; its name references Trump's reaction after the July 2024 assassination attempt.
Trump hosted a black-tie dinner on May 22, 2025 at his Virginia golf club for the top 220 TRUMP token holders, who spent a combined $148M to qualify. The largest holder was Justin Sun, a crypto entrepreneur whose SEC fraud case was paused on grounds of public interest. Bloomberg estimated that 19 of the top 25 holders were likely foreign nationals. Thirty-five House Democrats demanded a DOJ investigation into potential bribery and foreign emoluments violations. The Trump family had earned more than $320M in trading fees since the January launch, while about 764,000 wallets of small holders lost money. GD Culture Group, a company with Chinese ties, announced a $300M TRUMP purchase after Trump signaled a TikTok ban delay.
Participants and concerns included: Justin Sun, the Tron blockchain founder, whose SEC fraud charges were paused after he became the top TRUMP holder; GD Culture Group, a Chinese-linked company purchasing $300M in TRUMP tokens on a timeline that correlates with TikTok policy; a Houston shipping company that bought $20M to advocate U.S.-Mexico free trade; and Representatives Casten and Smith, who formally demanded a DOJ investigation citing bribery statutes and the emoluments clause. Cryptocurrency industry lobbyists expressed concern that the dinner jeopardized passage of the GENIUS Act stablecoin legislation. The token price dropped 16% the day after the gala.
CIC Digital LLC and Fight Fight Fight LLC (owned by CIC Digital + Celebration Cards LLC) collectively held 800M TRUMP tokens (80% of 1B supply). 6 insider wallets with staggered unlock schedules. CIC Digital and Celebration Cards receive trading revenue from all TRUMP trading. As of Feb 11 2026: 53% unlocked, mkt cap $1.68B at $3.14.
Per the Canary TRUMP Coin ETF S-1/A (SEC Registration No. 333-289857, filed February 13, 2026): Trump Organization-affiliated entities CIC Digital LLC and Fight Fight Fight LLC collectively initially owned 800,000,000 tokens across six wallet groups labeled 'Creators & CIC Digital 1-6.' Fight Fight Fight LLC is owned by CIC Digital LLC and Celebration Cards LLC, both of which receive trading revenue derived from TRUMP trading. The unlock schedule runs: Group 1 (36%), three-month cliff plus 24-month linear vesting; Group 2 (18%), six-month cliff plus 24-month linear; Group 3 (18%), 12-month cliff plus 24-month linear. The Trump Organization thus retains 80% of all TRUMP meme coin supply and earns ongoing trading fees; at the token's peak price, the insider allocation was worth several billion dollars.
GD Culture Group — a Nasdaq-listed company with Chinese ties, eight employees, zero revenue, and a TikTok storefront — announced a $300M investment in Bitcoin and the TRUMP meme coin, funded by a stock sale to an unnamed British Virgin Islands entity. The purchase placed Trump family revenue from a Chinese-linked buyer alongside Trump's concurrent negotiation of a TikTok ban with China. The company secured $300M from an undisclosed offshore investor to buy Trump-branded crypto. Representatives Casten and Smith cited the transaction in their DOJ investigation demand.
A GD Culture Group SEC filing confirms the $300M investment plan. The company trades on Nasdaq with eight employees, zero revenue, and a business model dependent on TikTok, a Chinese platform facing a U.S. ban. The $300M comes from a stock sale to an unnamed British Virgin Islands entity, and the timing coincides with Trump's TikTok negotiations. The structure routes undisclosed Chinese-linked capital into Trump family crypto assets through a Nasdaq-listed entity, which critics including Representatives Casten and Smith characterize as a potential foreign-influence channel. The arrangement parallels the UAE channel via Aryam/MGX.
identity (1)
A Trump Organization affiliate wholly owned by The Donald J. Trump Revocable Trust, CIC Digital LLC jointly owns Fight Fight Fight LLC with Celebration Cards LLC (Wyoming). CIC Digital holds the largest allocation of TRUMP token supply (36% in Creators & CIC Digital 1 tranche). CIC Digital and Celebration Cards, as owners of Fight Fight Fight LLC, receive revenue from TRUMP token trading fees. The entity also connects to Trump NFT ventures promoted by Bill Zanker.