CIC Digital LLC

CIC Digital LLC is wholly owned by The Donald J. Trump Revocable Trust, as disclosed in Trump's 2024 personal financial disclosure. 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

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

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

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.