Brian P. Brooks
Brooks is the archetypal vault-firm-to-regulator-to-vault-firm 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 actors' 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.
According to the Round 6 meta-synthesis adopted by this investigation, the three Brooks-era OCC interpretive letters are treated as live operative federal banking law that has been reanimated by 2025-era OCC personnel, including the October 15 2025 conditional approval of Erebor Bank, N.A., whose approval letter explicitly cites Interpretive Letters #1170 and #1174 as the legal scaffold for the new charter 34. According to the Round 6 analytical framework durable-deregulation-scaffolding, Brooks is treated as the canonical instance of a vault-firm or industry-alumnus regulator who authors 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 arc 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 the 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. According to investigation records, Brooks 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. According to the OCC tenure record, 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. According to the Round 6 meta-synthesis, his successor Acting Comptroller Michael Hsu issued Interpretive Letter #1179 in November 2021 attempting to claw back the framework via a supervisory non-objection requirement, a structurally reversible measure 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.
According to the Round 6 meta-synthesis, the three letters together constitute the precise federal-bank legal scaffolding required 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. According to examination of the October 15 2025 OCC conditional approval letter for Erebor Bank, N.A., the bank's organizers explicitly invoke 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)
According to the OCC tenure record, 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. According to the Round 6 synthesis, Anchorage's charter functions as the prototypical vehicle authorized under the Brooks-era interpretive framework, and according to the same record Anchorage was subsequently subjected to an OCC consent order in April 2022 over anti-money-laundering deficiencies 6.
According to cross-reference of the Round 6 record, 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. According to examination of the Erebor approval letter from October 15 2025, the OCC imposed 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. According to the Round 6 synthesis, the elevated capital condition is interpreted 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. According to Companies House records for Bitfury Group Limited (UK 11441275) retrieved May 7 2026, Brooks is a current director with appointment date December 20 2021, eleven months and six days after his departure from the OCC on January 14 2021 2. The current four-person board of Bitfury Group Limited 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.
According to Companies House filings, on December 23 2024 Bitfury Group Limited approved share-premium cancellations and a dividend of approximately 53.9 million dollars, with a related September 30 2024 share-premium cancellation effective March 1 2024 2. According to the Round 6 systemic synthesis, the Bitfury Group Limited board functions as a quiet structural axis tying together 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. According to the same Round 6 synthesis, the board has produced two consecutive ex-Bitfury alumni who have subsequently held senior positions at the OCC, namely Brooks in 2020 and Jonathan Gould in 2025 7.
Brian P. Brooks
Strategy Board Appointment and December 2024 Pre-Positioning
According to OCC tenure records and Strategy Inc disclosures, on December 20 2024 Brooks was appointed to the board of directors of Strategy Inc (formerly MicroStrategy, Nasdaq: MSTR), the bitcoin-treasury vehicle led by Michael Saylor 1. According to the Round 6 systemic synthesis, the Strategy 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.
According to a Round 6 systemic finding, the August-to-December 2024 window contains a synchronous cluster of US Delaware-domiciled holding-company filings by four members of the Round 6 fifteen-actor system: 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. According to the same systemic finding, the temporal coincidence of these filings with Aryam Investment 1's January 16 2025 World Liberty Financial transaction and the January 21 2025 Stargate AI-infrastructure announcement is the basis for the Round 6 attribution of a coordinated pre-positioning window rather than an unrelated sequence of corporate events 8.
Reanimation of Brooks-Era Interpretive Letters by 2025 OCC Personnel
According to the Round 6 meta-synthesis, the Brooks-era interpretive-letter framework has been reanimated by 2025 OCC personnel rather than rewritten 4. According to the same Round 6 record, the principal documented vehicle of that reanimation is the OCC conditional approval of Erebor Bank, N.A. on October 15 2025 3. According to examination of the Erebor approval letter (recorded under OCC Control Number 2025-Charter-342076 and Charter Number 25357), Wendy Goldberg of Skadden Arps Slate Meagher Flom LLP is named as counsel of record, and the letter 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.
According to the Round 6 systemic synthesis, the Erebor approval is structurally connected through three documented revolving-door links to the Brooks-era OCC 6. According to the same synthesis, 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. According to the Round 6 framework adopted by this investigation, Brooks is treated as the canonical instance of durable-deregulation-scaffolding, 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
According to investigation records, Brooks's structural significance is not the eight-month Acting Comptroller tenure itself but the durability and reach of the three interpretive letters issued under his signature 1. According to the Round 6 meta-synthesis, the same three letters function across administrations as live operative federal banking law rather than as a withdrawn or superseded framework 4. According to examination of the October 15 2025 Erebor approval letter, Interpretive Letters #1170 and #1174 remain the controlling legal interpretations under which the OCC currently authorizes national-bank crypto-custody and validator-node activity, and the additional 2025 letter (Interpretive Letter #1184, issued May 7 2025 under the Hood/Gould OCC) extends rather than replaces the Brooks framework 3.
According to the Round 6 systemic synthesis, two ex-Bitfury alumni have now occupied senior OCC positions across two administrations, namely Brooks as Acting Comptroller in 2020 to 2021 and Jonathan Gould as confirmed thirty-second Comptroller from July 10 2025, with the same UK private company (Bitfury Group Limited, Companies House 11441275) and the same UAE-anchored ownership structure as the shared institutional anchor 7. According to the Round 6 framework, the two-instance Bitfury-to-OCC pipeline combined with the explicit citation of Brooks-era letters in 2025-era charter approvals supports treating Brooks's regulatory output as a persistent deregulatory product rather than as 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)
SYSTEMIC: Bitfury Group Ltd UK 11441275 board is a quiet structural axis tying des Pallieres (OneIM Misra) + Brooks (ex-OCC, MicroStrategy) + Vavilov; AND a recurring Bitfury -> OCC Comptroller pipeline runs through it (Brooks 2020 Acting; Jonathan Gould 2025-, ex-Bitfury exec)
Members of the 15-actor system on or via the Bitfury Group Ltd UK 11441275 board: Bertrand Gauquelin des Pallieres (director + 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), 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 is observed TWICE: (1) 2020 Brooks (Bitfury board -> OCC Acting Comptroller, designed Interpretive Letters 1170/1172/1174 stablecoin/crypto-bank framework that scaffolds Tahnoon-WLFI deals); (2) 2025 Jonathan Gould (Jones Day -> Bitfury exec -> confirmed 32nd Comptroller Jul 10 2025 -> granted Erebor 'first full-service national bank charter in four years'). Two separate Bitfury alumni install themselves as crypto-banking regulator. des Pallieres - through whom Misra met Benedetti and who is now OneIM Partner Private Credit (Mubadala-anchored) - sits on the same Bitfury board. Bitfury operates as the sub-rosa institutional bridge between Tahnoon-cluster crypto-policy capture and US bank-regulator personnel - independent of Epstein. Falsifies a Brooks-coincidence read; supports an institutional-pipeline read.
SYSTEMIC: A Delaware-Aug-2024 holding-company registration window catches FOUR of the 15 actors (Brooks via Strategy MSTR board appointment Dec 20 2024; Klein via AltC SPAC family; Hussaini + Ben Black via Fortinbras Enterprises LP Delaware) - this is a structural pre-positioning window that immediately precedes Misra's Nov 12 2024 SoftBank exit + OneIM Nov 19 2024 8B upsize
Within +/- 90 days of Misra's formal SoftBank exit (Nov 12 2024) and OneIM's Nov 19 2024 8B upsize, four of the 15 system actors took new structural positions in US Delaware holding-co architecture: (1) Aug 2024: MGX Fund Management LLC registers in DELAWARE (Mubadala-affiliated UAE sovereign vehicle, also NY Sept 2024 #3803). (2) Sept 2024: Leon Black opens 'Scimitar' family office at ADGM ('Elysium's first international office'); Ben Black + Asad Hussaini named as principals. Fortinbras Enterprises LP (Delaware, credit platform, named for Hamlet's foreign avenger). (3) Dec 20 2024: Brian P. Brooks joins MicroStrategy / Strategy (NASDAQ MSTR) board alongside Galaxy Digital director - Strategy is Saylor's bitcoin-treasury vehicle and pre-positioning for stablecoin issuance under Brooks' 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. THE WLFI-Aryam-MGX axis: 16 Jan 2025 Aryam-WLFI signed (Tahnoon's UAE 49% stake in Trump-family DeFi via G42 executives); 21 Jan 2025 Stargate B AI-infrastructure JV announcement (Trump-Son-Altman) - Misra positioned through OneIM to intermediate. SIGNIFICANCE: the Aug-Dec 2024 window is a coordinated pre-positioning of US-domestic regulatory + holding-co architecture by Tahnoon-Mubadala-anchored capital. Klein - although co-cited with Misra/Benedetti at Hotel Baur au Lac Nov 2017 - sits structurally adjacent (AltC SPAC + Churchill Capital + Strategy/MSTR via M. Klein & Co), not inside, the Mubadala flow.
intelligence (3)
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.
discover-frameworks Round 6 cycle: 5 framework candidates evaluated, 3 adopted as Tier-2 lenses
Anchored on Round 6 meta-synthesis finding #11236 (seven cross-lens patterns from Agents A-G). Reviewed existing inventory of 8 core models + 28 Tier-2 lenses. Candidates: (1) Durable Deregulation Scaffolding [adopted] — OCC interpretive letters as persistent legal artifacts that survive administrations and are reanimated by counsel from issuing firm; 4 instances Brooks 2020 IL #1170/1174, IL #1184 cited in Erebor approval 2025. (2) Announcement Bundling [adopted] — pre-existing infrastructure repackaged as 'new' announcement creating the price-moving event; Stargate cluster: Bitfury Dec 2024 dividend 38d before Cipher PIPE, AltC May 2024 anomalous redemption, Crusoe Jun 2024 Abilene construction (7mo pre-announce), SoftBank full Cipher exit Q3 2025. (3) Controlled Detachment [adopted] — visible-loss substitution that maintains/extends structural capability; bin Sulayem out Feb 13 2026 + Kazim into Nasdaq Inc. board via Borse Dubai = US-market access extended. Candidates evaluated: (4) Narrative-Filing Divergence [tier-3 reference] — press-merge of structurally separate SEC filings (Stargate-MGX, Klein-Altman-Oklo). (5) Asset-as-Compensation Channel [candidate] — specific real assets (Italian villa via UK Harbour vehicles) substituting for cash compensation in opaque service relationships. Source-quality decay function noted as methodology improvement, not a framework.
identity (2)
Brian P. Brooks is the highest-leverage technocrat-asset in the Trump 2.0 crypto-policy stack — designed the OCC crypto-banking framework (Interpretive Letters #1170/#1172/#1174); now sits on Bitfury board with des Pallieres + UAE-resident Vavilov + Georgian Kikvadze; joined MicroStrategy/Strategy board Dec 20 2024 (34 days before SoftBank-Cipher Star Beacon $50M PIPE)
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 BROOKS FRAMEWORK at OCC: 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) tried to claw these back via supervisory non-objection — easily reversible by a Brooks-aligned 2025+ OCC. These three letters are the precise legal scaffolding required for WLFI/USD1 stablecoin, Tahnoon-DTR/DRAM, MGX-Stargate, and any other actor seeking national-bank crypto rails. TRUMP 2.0: met Trump in person Nov 2024; 40% lead candidate on Kalshi for SEC Chair (Atkins ultimately selected); considered for proposed first-ever White House Crypto Advisor role. OneWest pre-Trump-1.0 Mnuchin connection adds GOP/financial-nominee provenance line. 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) — coordinated positioning. Concurrent boards (MSTR-Saylor bitcoin treasury / HBAR smart-contract L1 / Bitfury mining infrastructure / Meridian mortgage-GSE) form a four-dimensional surface mapping the Trump-2.0 crypto policy agenda.
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. CRITICAL 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, 19/16/15 Feb 2024 — capital structure being actively restructured. Filing 4 Aug 2025 retroactively backdated des Pallieres details to 1 Feb 2023 — investigative interest.
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.