At least some of the top holders of Donald Trump's memecoin, who are eligible to apply for a private dinner with the former president, appear to be based outside the United States.

A Bloomberg analysis found that 19 of the top 25 wallets on the TRUMP token leaderboard used foreign crypto exchanges that do not allow U.S. customers, hinting these holders could be foreign nationals or Americans living overseas.

At least some of the top holders of Donald Trump’s memecoin, who are eligible to apply for a private dinner with the former president, appear to be based outside of the United States.

A Bloomberg analysis found that 19 of the top 25 wallets on the TRUMP token leaderboard used foreign crypto exchanges that do not allow U.S. customers, hinting these holders could be foreign nationals or Americans living overseas. More than half of the top 220 wallets that are eligible for the dinner also used such platforms.

The TRUMP memecoin was launched on January 17, three days before Trump’s inauguration. On April 23, the team behind the coin announced that the top 220 token holders would be invited to a May 22 dinner at Trump’s Virginia golf club, with the top 25 getting access to a VIP tour and reception.

However, the identities of the holders remain unknown, with only short usernames like “Sun,” "MeCo," and "JIGL" being listed on the coin’s site. But a deeper analysis of SolScan and Dune data showed that at least 76% of the token value held by the top 220 wallets likely comes from overseas accounts.

After the dinner announcement, the coin’s price jumped from around $9 to $14, with more than 400 transactions over $100,000 occurring in just five days. One foreign wallet made two purchases worth $3.6 million just hours after the event was announced.

The website says that applicants must pass a background check and cannot be from countries flagged on Know Your Customer (KYC) watchlists. Still, it is unclear how organizers will screen wallets or attempt to verify identities. Attendees must use self-custodied wallets and cannot bring guests.

The initiative has sparked concerns among lawmakers, with Senator Elizabeth Warren and Representative Adam Schiff writing to the Justice Department and Federal Election Commission to investigate. In their letter, they recently called for an investigation and warned that the event could be "pay-to-play corruption."

"This pay-to-play scheme poses a severe risk to our democracy and must be investigated fully and immediately," the officials said in a joint statement.

One senator went as far as to call for impeachment, saying that Trump is "selling access for what are effectively payments directly to him."

Meanwhile, the House Democrats walked out of a cryptocurrency hearing to protest a lack of action on issues such as abortion rights and voting.