Sheikh Tahnoon bin Zayed Al Nahyan

Sheikh Tahnoon bin Zayed Al Nahyan was born December 4, 1968, in Abu Dhabi; some sources cite 1971, but the December 4, 1968 date appears in OpenSanctions primary records ³. He is the son of UAE founder Sheikh Zayed bin Sultan Al Nahyan and a full brother of UAE President MBZ. His formal government title is UAE National Security Adviser. He holds the title of Deputy Ruler of Abu Dhabi ¹.

His formal institutional chairmanships as of early 2026 include: Abu Dhabi Investment Authority (ADIA), MGX Fund Management Limited, G42 (Group 42), International Holding Company/IHC (listed on ADX), ADQ (Abu Dhabi Developmental Holding), First Abu Dhabi Bank, and Judan Financial Holding (announced February 2026, consolidating Chimera, Lunate, and International Securities into a 237-billion-AUM financial services group across 13 countries) ¹. He sits on the Mubadala board. According to corporate disclosures, his private vehicle, Royal Group Holding, owns 61% of IHC and 100% of G42 ⁸. UK Companies House records document officer appointments associated with his name ⁹.

OpenSanctions flags two distinct Tahnoon Al Nahyan individuals: the subject of this dossier (DOB 1968-12-04, national security adviser) should not be confused with Tahnoon bin Mohammed Al Nahyan (born 1942, died 2024), his uncle, who held different posts ³.

Tahnoon’s “Spy Sheikh” designation reflects his oversight of UAE offensive cyber programs, including DarkMatter Group (2015–2019). DarkMatter was staffed by former NSA, CIA, and Israeli intelligence officers and ran Project Raven, a UAE surveillance operation that targeted dissidents, journalists, and Americans. Three former Project Raven contractors — Baier, Adams, and Gericke — were criminally charged by the US Department of Justice under export control laws ¹⁰.

G42 absorbed substantial DarkMatter personnel and infrastructure as the latter wound down. G42 CEO Peng Xiao had previously served as CEO of Pegasus LLC, a DarkMatter subsidiary; Pax AI, a G42 subsidiary, is a rebranding of Pegasus itself ¹⁰. G42 created the ToTok messaging application (originally branded G42 IM, rebranded July 2019) through Breej Holding — whose sole director is Tahnoon’s adopted son — and the application was identified by US intelligence as a UAE mass surveillance tool ¹⁰. The CIA opened an investigative file on Peng Xiao; the House Select Committee on CCP documented that Xiao operates a network of UAE and PRC-based companies developing dual-use technologies supporting PRC military-civil fusion ¹¹.

G42’s CIO Zhang Xiaoping maintained simultaneous roles at Yitu Technology, a US-sanctioned Chinese AI and surveillance firm, while G42 held Microsoft’s $1.5 billion investment and a WLFI board seat ¹⁰. Congressional testimony and Commerce Department records indicate that the primary US national security concern was the potential diversion of advanced Nvidia chips supplied to G42 or MGX into Chinese military-civil fusion programs ¹².

Tahnoon controls his commercial empire through three overlapping ownership chains. The first is his private vehicle: according to corporate disclosures, Royal Group Holding owns G42 outright and holds 61% of IHC ⁸. IHC (Abu Dhabi Exchange-listed, $250 billion conglomerate) contains 2PointZero, a $27 billion holding company that itself holds Chimera Investment LLC and Lunate Capital. According to ADX market data, IHC’s share price grew approximately 42,000% between 2019 and 2024 ². Judan Financial Holding, announced February 2026 with Tahnoon as chairman, consolidates Chimera, Lunate, and International Securities into the new structure across 13 countries with $237 billion AUM ¹.

The second chain is sovereign: Tahnoon chairs ADIA (multi-trillion sovereign wealth fund), ADQ (state development holding), and FAB (First Abu Dhabi Bank). Mubadala Investment Company, the sovereign wealth fund, co-founded MGX with G42 in March 2024; Tahnoon chairs MGX and Mubadala vice-chairman Khaldoon Khalifa Al Mubarak serves as MGX Vice Chairman ¹³.

The third chain is the investment intermediary tier: Aryam Investment 1 (the WLFI acquisition vehicle) is incorporated as two identically named entities, one in Delaware and one in Abu Dhabi. The Delaware entity is managed by Martin Edelman (G42 General Counsel) and Peng Xiao (G42 CEO), both of whom also serve on the MGX board ¹⁴. Alpha Wave Global — nominally independent but whose primary capital derives from Tahnoon’s sovereign vehicles (IHC/Alpha Dhabi is sole LP of the $10 billion Alpha Wave Ventures II fund) — participated in the TikTok USDS restructuring through Alpha Wave Partners LLC ¹⁵.

An internal transfer in 2024 is relevant to the divestiture question: the 42XFund, a G42-originated $10 billion Shanghai-based fund holding stakes in ByteDance and JD.com, was transferred to Lunate (IHC subsidiary) in July 2024, formally satisfying G42’s divestiture commitment to the Biden administration and Commerce Department Bureau of Industry and Security though the economic interest remained within the broader Tahnoon ownership structure ^{16 17}. Lunate thereby held ByteDance equity while MGX simultaneously held 15% of TikTok USDS JV — Tahnoon entities on both sides of the TikTok restructuring ¹⁸.

Five confirmed financial transactions link Tahnoon-controlled entities to ventures whose regulatory conditions were influenced by Trump administration actions between January 2025 and February 2026.

WLFI acquisition (January 2025). Four days before inauguration, World Liberty Financial signed an agreement with Aryam Investment 1 giving Tahnoon’s entity a 49% stake for $500 million. Eric Trump signed for WLFI; Martin Edelman and Peng Xiao signed for Aryam ¹⁹. According to financial disclosures, approximately $187 million flowed to Trump family entities from this transaction ¹². Aryam thereby secured two of five WLFI board seats, occupied by Edelman and Xiao, without public disclosure ¹⁹. Records show that in May 2025, the Trump administration approved the annual sale of 500,000 advanced Nvidia AI chips to the UAE — reversing the Biden administration’s refusal on the same request — with 100,000 chips allocated directly to G42 ¹². According to Senator Warren, the arrangement constituted “corruption, plain and simple” ¹².

MGX-Binance investment (March 2025). MGX invested $2 billion in Binance, the world’s largest cryptocurrency exchange, with the transaction settled using the USD1 stablecoin issued by World Liberty Financial. WLFI confirmed that MGX and Binance would have used foreign fiat currency had USD1 not been available, making the use of the Trump family’s stablecoin a deliberate selection ²⁰. According to White House records, Binance founder Changpeng Zhao (CZ) was pardoned by President Trump in October 2025 ². Senators Warren and Merkley sent document-preservation demands to MGX and Binance asking whether Trump or WLFI affiliates influenced the USD1 selection ²⁰.

Stargate commitment (January 2025). MGX committed $7 billion to Stargate LLC, the $500 billion AI infrastructure joint venture announced at the White House on January 21, 2025, alongside SoftBank ($19 billion), OpenAI ($19 billion), and Oracle ($7 billion) ²¹. G42 serves as a key operator for Stargate UAE, launched in May 2025 with Sam Altman — who described Tahnoon as a “dear personal friend” ²². The Stargate JV requires ongoing US government forbearance from antitrust enforcement and continued willingness to export advanced AI chips to the UAE to be viable ²³.

TikTok USDS restructuring (September 2025 – January 2026). Trump approved a TikTok US restructuring in September 2025 in which Oracle, Silver Lake, and MGX collectively held approximately 45% of the new US entity ²⁴. Alpha Wave Partners LLC (Rick Gerson, backed primarily by Tahnoon’s IHC) participated as a separate investor in the same restructuring ²⁵. Because Lunate (IHC subsidiary) continued to hold ByteDance equity through the 42XFund, Tahnoon entities held economic interest on both the ByteDance parent side and the TikTok US restructured side simultaneously ¹⁸.

OpenAI rounds (October 2025 and February 2026). MGX participated in OpenAI’s $6.6 billion funding round at a $500 billion valuation in October 2025 and co-led the $30 billion round in February 2026 ¹. MGX also participated in the Anthropic $30 billion funding round in February 2026 alongside Coatue and GIC ²⁶.

Martin Edelman is General Counsel of G42, a board member of MGX, an adviser to Mubadala, and Of Counsel at Paul Hastings LLP. He served as lead negotiator alongside Peng Xiao, Tahnoon, and UAE Ambassador Al Otaiba in the Biden-era discussions with the Bureau of Industry and Security over G42’s China divestiture ²⁷. He signed both the Aryam-WLFI agreement and holds a WLFI board seat alongside Peng Xiao. He also appears in an Epstein calendar from December 2016, and in a 2017 Epstein email list labeled “list for bannon steve” — a connection that predates his current Tahnoon roles by several years ²⁸.

Peng Xiao is Group CEO of G42 and a co-signatory of the WLFI agreement. He previously ran Pegasus LLC, a DarkMatter subsidiary, renounced his US citizenship for Emirati citizenship, and is the subject of a CIA classified report. Pegasus Technology Beijing, where Xiao serves as executive director, is a G42 Chinese subsidiary ²⁹.

Khaldoon Khalifa Al Mubarak is Vice Chairman of MGX and Mubadala CEO. He is the same Khaldoon Al Mubarak to whom MBZ delegated digital currency matters in October 2017, as documented in Epstein network emails from EFTA02586299 ³⁰. He bridges the Epstein-era Abu Dhabi institutional interface and the current MGX-WLFI structure ³¹.

Rick Gerson co-founded Alpha Wave Global (originally Falcon Edge Capital, 2012) with Navroz Udwadia. Alpha Wave’s primary capital comes from Tahnoon’s IHC/Chimera/Lunate vehicles ¹⁵. Gerson attended a secret December 2016 meeting between Trump transition officials (including Jared Kushner) and Crown Prince MBZ at the Four Seasons in New York, was in the Seychelles in January 2017 during the Erik Prince-Kirill Dmitriev meeting investigated by Robert Mueller, and came under Mueller investigation scrutiny for those contacts ³². UAE officials describe him as “Kushner’s guy” and he serves as a bridge between both the Abu Dhabi channel and the Saudi PIF-Kushner channel ³².

No FARA registration exists for MGX, Aryam Investment 1, G42, Tahnoon personally, Steve Witkoff, or Zach Witkoff in connection with the WLFI transaction or subsequent chip export and crypto regulatory actions ³³. The UAE has multiple FARA-registered agents for other purposes (Akin Gump, DLA Piper, Fleishman-Hillard, theGroup DC LLC for the UAE Ministry of Investment as of December 2025), but none cover the WLFI-crypto-AI chip nexus ³³.

The precedent case is United States v. Barrack (EDNY 1:21-cr-00371): Tom Barrack, Trump’s inaugural committee chair, was charged with acting as an unregistered UAE foreign agent; his co-defendant Rashid Al Malik Alshahhi is a UAE national whose case file in CourtListener references “Tahnoon,” connecting Tahnoon to the earlier lobbying operation ³⁴. Barrack was acquitted in October 2022; the Alshahhi case remains open ³⁴. Elliott Broidy pleaded guilty to FARA conspiracy for UAE and Saudi lobbying in a separate matter and received a Trump pardon in January 2021 ³⁵. The WLFI channel uses commercial crypto investment rather than traditional political consulting as the transaction mechanism, but the structural pattern — UAE sovereign capital flowing to Trump-connected individuals outside FARA — mirrors both precedents ³⁵.

Steve Witkoff’s dual position is of particular relevance to FARA analysis: as Trump’s Middle East Envoy he holds direct diplomatic access to Tahnoon, while his family simultaneously receives 12.5% of WLFI net protocol revenue from Tahnoon’s $500 million investment ³⁶. No recusal or ethics disclosure has been identified for Witkoff specific to his UAE diplomatic role and the WLFI revenue stream ³⁶.

G42’s China ties were the primary basis for Biden administration concerns about Nvidia chip exports to the UAE. G42 had partnered with BGI Genomics (Chinese genomics company with military ties), co-invested with Sinopharm in COVID vaccine manufacturing, operated two direct Chinese subsidiaries run by G42 CIO Zhang Xiaoping (who simultaneously held a role at US-sanctioned Yitu Technology), and launched the $10 billion 42XFund with ByteDance and JD.com stakes from a Shanghai base ³⁷.

In February 2024, G42 announced divestiture of all Chinese investments as a condition of Microsoft’s $1.5 billion investment and informal Commerce Department clearance. However, the 42XFund was transferred to Lunate (under IHC, which is majority-owned by Tahnoon’s Royal Group) in July 2024 rather than sold to an unrelated third party ¹⁷. The transfer was lateral within the same ownership structure: G42 and Lunate are both ultimately controlled by Tahnoon ¹⁶. A CFIUS review of G42’s stake in Cerebras Systems (an AI chip company) delayed Cerebras’ IPO until March 2025, when CFIUS cleared the structure only after G42’s stake was converted to non-voting shares ³⁸.

The Trump administration’s May 2025 decision to approve 500,000 advanced Nvidia chips annually to the UAE — with 100,000 going directly to G42 — reversed the Biden administration’s denial of the same request. Records indicate that the reversal came four months after Tahnoon’s $500 million WLFI investment and amid active Congressional scrutiny of the sequence ¹². Representative Ro Khanna stated publicly that UAE officials were lobbying the Trump administration to reduce export controls while simultaneously buying a stake in the Trump family’s business ³⁶.

The Abu Dhabi institutional infrastructure now channeling capital through MGX and WLFI intersected with the Epstein network in documented ways nearly a decade earlier. A October 2017 Epstein email ³⁹ shows David Stern reporting to Epstein that “MBZ handed [digital currency matters] to Khaldoon” — the same Khaldoon Al Mubarak who is now MGX Vice Chairman ³⁰. The same email seeks to broker a meeting between Leon Black (Apollo) and the Chairman of Abu Dhabi Global Markets ³⁰.

Ian Osborne, who sat on the Mubadala board, is documented in Epstein records coordinating tech investments during the same period. Martin Edelman appears in an Epstein calendar from December 2016 and in a 2017 email list ²⁸. The same sovereign architecture — MBZ, Mubadala, Khaldoon — that Epstein’s network sought to access on digital currency and investment brokering in 2017 is the same architecture behind MGX’s 2025 crypto and AI infrastructure transactions ³¹.

Separately, Sultan Bin Sulayem (DP World chairman), who was an Epstein-era UAE connector, was FARA-registered through a firm employing Ari Ben-Menashe, an Israeli intelligence figure ³⁵. The pattern of UAE sovereign capital flowing to Trump-connected individuals outside FARA structures — from Barrack (2016–2018) to Broidy to the current WLFI channel — spans multiple administrations, with dollar amounts increasing in each successive instance ³⁵.