At least some of the top holders of Donald Trump’s memecoin who apply to attend a private dinner with the president could be based outside the United States.

According to a May 7 Bloomberg report based on an analysis of the top TRUMP tokenholders, 19 of the top 25 wallets on the leaderboard used foreign exchanges that exclude US-based customers, suggesting either foreign nationals or Americans living abroad. In addition, more than half of the top 220 holders — the group eligible to apply for a dinner with the president — also used exchanges in other countries.

Top 10 TRUMP memecoin holders as of May. 7. Source: Trump meme

As of May 7, the identities of the top tokenholders and those who might choose to apply for the May 22 Trump dinner and “special VIP tour” were unknown. However, the project stated that anyone who applied could not bring guests, had to pass a background check, and “can not be from a [Know Your Customer] watchlist country.” 

The implications of having dozens or hundreds of memecoin holders potentially tied to foreign governments and interest groups have raised ethics concerns from some US lawmakers, claiming that Trump was engaging in “pay-to-play” corruption. At least one senator has called for the president’s impeachment, saying Trump was “selling access for what are effectively payments directly to him.”

Memecoin concerns are slowing crypto legislation

Democratic lawmakers in the House of Representatives and Senate have already been pushing back against considering any crypto-related legislation until Republicans address concerns around “Trump’s crypto corruption.” The Senate is expected to vote on a bill regulating stablecoins on May 8, and House Republicans recently introduced a discussion draft of a digital asset market structure bill.

Related: Trump-backed USD1 is now the seventh-largest stablecoin worldwide

Then-president-elect Trump launched the memecoin on Jan. 17 — three days before taking office — followed by the first lady introducing her own token. Two companies connected to Trump control roughly 80% of the memecoin’s supply.

The launch of the memecoin and its potential influence over the president and his agenda has already prompted some companies to get on board. On April 30, a trucking logistics management company announced a $20 million investment in the TRUMP token, suggesting influencing Trump’s trade war between the US and Mexico, where the firm conducts much of its business.

Magazine: Trump’s crypto ventures raise conflict of interest, insider trading questions