More than 200 wealthy, mostly anonymous crypto people are heading to Washington D.C.

The ticket was expensive, with “winners” spending anywhere from $55,000 to $37.7 million on Trump's official cryptocurrency token #TRUMP

More than 200 people are heading to Washington D.C. on Thursday for a dinner with President Trump, and the ticket was expensive.

The "winners" spent anywhere from $55,000 to $37.7 million on Trump's official cryptocurrency token, according to data from blockchain analytics firm Nansen.

Dinner organizers determined eligibility for a seat based on how many TRUMP tokens a person holds at a given point in time. Nansen found that the "winners" spent a total of $394 million on Trump's official cryptocurrency, though some of them sold some or all of their holdings after the contest ended.

Of course, the spending varied widely: the top seven spent more than $10 million each, while the bottom 24 spent less than $100,000 each.

The study showed that one-third (67) of the "winners" spent more than $1 million, with an average of $1,788,994.42 per "winner."

Like many meme coins, $TRUMP's value has fluctuated wildly, according to CoinMarketCap, which tracks cryptocurrency prices. Nansen tracked how much each "bidder" spent when buying $TRUMP.

The 220 buyers were invited to a dinner at the Trump National Golf Club (Washington, D.C.), and although the competition website states that Trump "attended the dinner as a guest and did not raise funds for it," it also points out that 80% of the $TRUMP token project is owned by two Trump-related companies - CIC Digital and Fight Fight Fight LLC.

The personal cryptocurrency and related bidding, which ended last Monday, added to Trump's apparent use of his presidency for personal gain.

His business interests are held in trusts controlled by his son, Donald Trump Jr., and he has intertwined many of the family businesses with his presidential activities, including hosting events at his social clubs (like the cryptocurrency dinner) and posting exclusive political statements on his social media app Truth Social.

Trump's cryptocurrency also generates revenue for its affiliated companies through transactions. Each $TRUMP token transaction generates a transaction fee. Another cryptocurrency research firm, Chainalysis, estimates that $TRUMP tokens generated nearly $900,000 in transaction fees in the first two days after the competition was announced.

Dan Weiner, director of the Elections and Government Program at the Brennan Center for Justice, told NBC News that while most federal employees are prohibited by law from using their positions for financial gain, the president is largely exempt.

“The president is not subject to the broad conflict of interest prohibitions that apply to nearly every other federal government worker,” Weiner said. “Overall, this is pretty crazy even by the standards of the first Trump administration, when all kinds of people were doing business at the president’s hotels. This is way beyond that, but it doesn’t necessarily mean he’s breaking the law.”

“The president is working to get a better deal for the American people, not for himself,” White House spokeswoman Anna Kelly said in a statement. “President Trump is acting only in the best interest of the American public — which is why they overwhelmingly re-elected him to office despite facing years of lies and false accusations about him and his businesses from the Fake News Media.”

Even the winner at the bottom of the list spent far more than the $3,500 limit that American citizens can legally donate directly to political candidates.

On Tuesday, the top spender was revealed to be crypto entrepreneur Justin Sun, who told Forbes in March that he had become a citizen of the small Caribbean island nation of St. Kitts and Nevis. Sun was sued by the U.S. Securities and Exchange Commission (SEC), but the case was suspended during the Trump administration.

The identities of most other contest winners remain undisclosed, known only by their pseudonyms and cryptocurrency wallet addresses. However, according to analysis by independent crypto researcher Molly White, most of the attendees appear to be foreign nationals. Molly White tracked the transactions of each winning wallet across different cryptocurrency exchanges and noticed that the holders appeared to use exchanges that are not legally allowed to be used by U.S. citizens.

Molly White told NBC News that of the 220 wallets associated with the bid winners, 158, or 72 percent, appeared to be foreign wallets.

A New York Times investigation reported that the list of winners included representatives of cryptocurrency businesses from Singapore and Australia.

Dan Weiner noted that the high percentage of non-U.S. citizens among the bid winners is noteworthy because it is generally illegal for non-U.S. citizens to donate to U.S. political candidates.

“It’s an incredible contrast,”