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
Warren's letter frames the underlying concern as whether the OCC's process "may have been contaminated by backroom political manipulation" — described as potentially "a corrupt political favor to the President's billionaire supporters in Silicon Valley." 1 These are direct quotations from the letter, presented with attribution; the language reflects the Senator's framing rather than an independent finding by this investigation.
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 That possibility is an inference drawn from the documented 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 record 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
Review of the records situates the Cohen-Skadden-OCC sequence as the third documented instance of attorneys moving from private financial-regulatory practice into the OCC and then encountering matters tied to their former clients, alongside Brian Brooks (Coinbase to OCC Acting Comptroller in 2020) and Comptroller Jonathan V. Gould (Bitfury and BlackRock to OCC Comptroller in 2025). 2 Examination of the same material identifies a separate pattern at the Office of Management and Budget, running through Mark Paoletta (private practice to OMB General Counsel in Trump I, then Schaerr Jaffe LLP, then back to OMB with concurrent Consumer Financial Protection Bureau and Office of Information and Regulatory Affairs roles in Trump II). 3 Of the OCC instances, Cohen's is the most compressed in time: cross-reference of the filings places the interval from Erebor charter filing to OCC appointment to charter approval at sixty-one days followed by a further sixty-five 2. This grouping reflects the investigation's own analysis of the documented timeline rather than a conclusion reached by an outside 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 The investigation reads the same Brooks-era interpretive-letter framework as underpinning the OCC posture toward stablecoin and tokenization activity associated with World Liberty Financial and the Tahnoon vehicle Aryam Investment 1, which acquired a 49% WLFI stake. 1 That linkage is investigative inference rather than a finding adjudicated by an outside authority.
The structural significance of Cohen's role, on this reading, is that a legal scaffold authored under Brian Brooks at the OCC, then carried into private practice and corporate-counsel posts, has returned to the OCC as the live framework now applied by personnel — including Cohen and Comptroller Gould — drawn from the firms and companies that benefit from it. 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)
Three documented revolving-door links converge on the Erebor charter (Cohen/Skadden, Mónica/Anchorage, Gould/Bitfury), all operating within the same Brooks-era interpretive-letter framework; Warren's Feb 2026 letter characterizes the approval as a 'corrupt political favor'
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, defense), Palantir (Thiel/Lonsdale, data analytics), and a 'concentrated set' of crypto, AI, and defense companies. The bank opened Feb 8 2026 without a Chief Risk Officer (Rosenberg listed in the approval letter; Warren Q12 confirms departure before opening). The progression from Bitfury to the OCC and then to a charter favorable to that orbit runs through Skadden as the connecting legal advisor.
Seven cross-cutting patterns across the SoftBank-caper and Epstein-replatforming material. (1) The financial-regulatory revolving door runs across four instances: three moves from private practice into the OCC and out to implementation (Brooks 2020, Coinbase to OCC to Bitfury; Gould 2025, Bitfury/BlackRock/Promontory to OCC; Cohen 2025, Skadden to OCC to Erebor approval, with Cohen's 65-day window the tightest), plus a parallel route through the Office of Management and Budget via Paoletta (2018 and 2025) at OMB, CFPB, and OIRA, which is structurally distinct from the OCC sequence. (2) Brooks-era Interpretive Letters #1170/#1174 and IL #1184 remain operative law, cited in the Erebor approval letter; the same deregulatory framework now underpins 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 in WLFI USD1 to Binance in May 2025. (4) The 'Mubadala unifies' model now 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 across ADX, SCA, and as ADGM Vice Chair), and a US-listing layer (Kazim as a Nasdaq Inc. director via Borse Dubai); these institutional bridges persist beyond the individuals who built them. (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 separate at the SEC primary-source level, though press treatment merged them; 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 setback for the Tahnoon network tied to Epstein-related exposure; his replacement Kazim maintains and extends US-market access via a Nasdaq Inc. board seat. Several earlier identifications are corrected: the 'Stéphane' reference resolves to Bertrand G. des Pallières; 'Antoine Bremner', previously unverified, is most likely Christopher Bremner; Compagnie Du Saleve (B223232) was incorporated in 2018 and so cannot be the 28 Oct 2015 entity, which is more likely the now-closed French SARL #803012046; SKAS denotes the Saker Aviation Services ticker rather than a partners' acronym; and the Hoffenberg-associated claim that 'Gold shielded Epstein' 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. A notable overlap: Diogo Mónica co-founded Anchorage Digital, the OCC's first crypto bank charter (Brooks era 2021), and Mosier is ex-FinCEN, so several of Erebor's independent directors helped build or regulate the framework now being applied to the bank.
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 the legal basis for holding non-asset-backed virtual currencies on balance sheet to pay 'gas fees' under 12 USC 24(Seventh). The Brooks-Gould interpretive-letter framework thus remains the operative legal basis 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