Trump’s Crypto Firm Took $100M from Businessman With Sketchy Past

NEWS & RESEARCH

In 2025, the company Aqua 1 became the largest investor in World Liberty Financial (WLF)—the crypto venture of President Donald Trump and his three sons—by buying $100 million in tokens. But Aqua 1's owner, Guren "Bobby" Zhou, is under active investigation in England, having been arrested on suspicion of money laundering. Prosecutors have not yet decided whether to charge Zhou, though every other individual identified in the indictment already has been. Chinese courts also found Zhou liable in three separate civil cases between 2017 and 2023 for failing to repay the equivalent of more than $2.4 million in loans. That Zhou had the funds to invest in WLF at all has "stunned" and confused the people who know him, who say he was "constantly asking for money" and that his past businesses—including a hardwood flooring retailer—had all failed. So how did he suddenly come up with $100 million to drop on Trump's firm? His company, Aqua 1, had no public history either: it was created and immediately invested in WLF. The source of Zhou's sudden fortune remains a mystery, but one thing is clear—many business professionals refused to work with him after researching his background. WLF, on the other hand, welcomed his firm with open arms: "We're excited to work hand-in-hand with the team at Aqua 1… Aligning with Aqua 1 validates our blueprint for global financial innovation."

SOURCES: New York Times | Reuters

ANALYSIS & OPINION

According to the New York Times, this case illustrates "the ease with which buyers with unknown backgrounds and motivations can use the anonymity of cryptocurrency to shower Mr. Trump with money." It also raises the question of whether WLF is violating the Bank Secrecy Act (BSA), the 1970 anti-money laundering law that requires “financial institutions” to document the source of a customer's funds before accepting the money. However, the BSA was adopted decades before crypto existed. The Treasury Department has said that crypto exchanges qualify as financial institutions, but has never declared whether the same rules apply to companies that issue their own tokens, as WLF does. This case sits in that gap but deserves closer scrutiny. After all, the red flags stack on top of one another: Zhou's business failures, his sudden access to wealth, the size of the transaction and the ongoing investigation against him. In fact, an official at a Swiss firm that investigates digital asset crimes explained that the involvement of the Trump family would typically trigger "the highest level of regulatory scrutiny available in the financial system," because international anti-money laundering laws classify the Trumps as "politically exposed persons" with a heightened vulnerability to influence peddling. And the relevance of this case extends well beyond Zhou: Trump's 2026 financial disclosure form shows he collected $1.4 billion from his crypto businesses the previous year, the majority of it from anonymous sources.

SOURCES: New York Times | Reuters

HOW TO FIX IT

Federal action:

• Designate crypto token issuers as financial institutions under the Bank Secrecy Act. The law's definition of "financial institution" ends with a catch-all letting the Treasury Secretary add "any other business…whose cash transactions have a high degree of usefulness in criminal, tax, or regulatory matters" (31 U.S.C. § 5312). The Department of Treasury has already used that power to bring crypto exchanges under the rules. Extending it to companies that issue their own tokens would settle the question surrounding this case. It takes rulemaking, not an act of Congress.

• Reintroduce and pass the Digital Asset Anti-Money Laundering Act of 2023, which would force the wallet providers and intermediaries that move crypto to verify exactly who is behind a transaction before accepting funds, making it far harder for an anonymous shell entity like Aqua 1 to route $100 million to the president's company without anyone documenting the true source of the cash. It would require crypto platforms to run background checks on customer identities, bringing unhosted wallets, miners, and decentralized finance (DeFi) networks under standard anti-money laundering rules.

• Reintroduce and pass the Crypto-Asset National Security Enhancement and Enforcement Act of 2023, which would hold decentralized finance platforms legally liable for ignoring obvious red flags by putting anti-money laundering and sanctions duties on whoever controls them. For instance, if a buyer with a history of loan defaults and an active money laundering investigation attempts a massive deal, the people running the platform would risk federal penalties for skipping the background check.

• Pass the Financial Technology Protection Act of 2025, which would create a dedicated interagency working group to track how bad actors use digital assets for illicit financial trades. Treasury, law enforcement, and national security agencies would coordinate to spot patterns like mysterious multi-million-dollar crypto purchases coming from newly created shell accounts, and recommend how to close the gaps that let them through.

• Pass the Presidential Conflicts of Interest Accountability Act, which would require the president, vice president, and their immediate families to divest conflicting assets into a genuine blind trust run by an independent trustee. This would have stopped Trump from profiting off the crypto company in the first place while still in office.

• Pass the Curbing Officials’ Income and Nondisclosure (COIN) Act, which would bar the president, vice president, senior executive branch officials, members of Congress, and their immediate families from issuing, sponsoring, or endorsing digital assets, from 180 days before service through two years after. It would also require stablecoin issuers to certify quarterly to the Office of Government Ethics that no official is profiting.

• Pass the End Crypto Corruption Act, which would prohibit the president, vice president, members of Congress, and their families from issuing, endorsing, or sponsoring crypto assets while in office.

• Pass the Modern Emoluments and Malfeasance Enforcement (MEME) Act, which would prohibit officials and their families from issuing or sponsoring coins and force the disgorgement of profits already earned. 

• Pass the Stop TRUMP in Crypto Act which would ban covered officials, their spouses, and their children from holding controlling stakes in digital assets, serving as officers of token issuers, or taking payment to promote coins. 

• Open a congressional investigation. Subpoena WLF's compliance file for the Aqua 1 transaction—what, if any, due diligence the company performed, what it knew about the money laundering investigation in England, and where the $100 million originated.

• Examine WLF under the anti-money laundering rules already on the books. International standards classify the Trumps as politically-exposed persons, requiring enhanced background checks and source-of-funds documentation from financial institutions dealing with them. Treasury and FinCEN—the Treasury bureau that writes and enforces the country's anti-money laundering rules—can open that examination today, without any new authority from Congress.

• Use existing money laundering law to freeze and seize the funds. Federal prosecutors could file civil forfeiture suits under 18 U.S.C. 1956 to confiscate the $100 million on grounds that it involves proceeds of suspicious overseas activity, compelling the investors to prove in court that the money is legitimate. The catch: the only office that can bring that case against a $100 million investment in the president's own company is the president's Justice Department.

State action:

• Pass strict state laws against anonymous crypto deals like New York's proposed Crypto Regulation, Protection, Transparency, and Oversight (CRPTO) Act, which would hold local exchanges legally responsible for who they take money from. Even without federal action, state-level regulations would force any crypto firm operating within their borders to conduct mandatory independent audits and verify big investors, making it illegal to take money from buyers they haven't vetted.

Legislation: S.2669 - Digital Asset Anti-Money Laundering Act of 2023 | S.2355 - Crypto-Asset National Security Enhancement and Enforcement Act of 2023 | H.R.2384 - Financial Technology Protection Act of 2025 | H.R.7207 - Presidential Conflicts of Interest Accountability Act | S.2143 - COIN Act | S.1668 - End Crypto Corruption Act | H.R.1712 - MEME Act | H.R.3573 - Stop TRUMP in Crypto Act | Crypto Regulation, Protection, Transparency, and Oversight (CRPTO) Act (New York)