Molly White

Today the SEC filed a proposed final judgment to settle their lawsuit against Justin Sun and his businesses for $10 million and no admission of wrongdoing.

Sun has spent between $112 million and $233 million on contributions to Trump-linked crypto firms.

Entity: Justin Sun and Tron // Benefit to entity: SEC enforcement case settled for $10 million fine with no admission of wrongdoing, Criminal investigation likely ended, Justin Sun added to World Liberty Financial advisory board, Tron to go public in the US in a $100 million deal brokered via Dominari Securities (where Eric and Donald Trump Jr. are board members) // Benefit to Trump and family: $100 million to purchase $TRUMP memecoins (announced but unconfirmed), $75 million to purchase $WLFI tokens from the Trump family's World Liberty Financial, $37.7 million to purchase $TRUMP memecoins (via HTX), $20 million to purchase shares of the Trump-linked Alt5 Sigma and more $WLFI (announced but unconfirmed), Listed USD1 for trading on HTX

In January, House Financial Services Ranking Member Maxine Waters sent a letter to SEC Chair Paul Atkins expressing concern over the SEC's "retrenchment from crypto enforcement", citing the Sun case and urging Atkins to hold him accountable.

The SEC Can Still Act to Hold Justin Sun Accountable One case offers the SEC an opportunity to demonstrate to Americans that the SEC still has their back. In February 2025, as part of its efforts to shut down cases holding crypto fraudsters accountable, the SEC asked the court to stay its enforcement action against Justin Sun, founder of the Tron Foundation, SEC v. Sun, et al., Case No. 1:23-cv-02433-ER (S.D.N.Y.). Unlike the other cases detailed above, this case has not yet been dismissed. The SEC’s request to stay the Sun litigation, and subsequent efforts to settle the matter, may have been unduly influenced by Sun’s relationship with the Trump family, including his significant financial contributions to their businesses.19 So that investors harmed by Sun‘s fraudulent activities may be made whole, I ask the to SEC revisit its request to stay its litigation against Sun and renew that action.

The SEC’s failure to hold Sun accountable suggests that it may be part of a pay-to-play scheme orchestrated by Sun. Specifically, as recently as September 5, 2025, Sun made statements on X suggesting he intended to purchase an additional $10 million worth of $WLFI tokens from World Liberty Financial (WLF), a Trump family business, in an apparent effort to persuade WLF that he is committed to the project, that they should unlock his 545 million $WLFI tokens, and to otherwise curry favor with the Trump family. We are also concerned that a settlement favorable to Sun could undermine U.S. securities regulation and threaten the integrity of U.S. markets by a person and entities located in the People’s Republic of China. On the heels of President Trump’s pardon of Binance founder, CZ, the SEC must continue to pursue material securities fraud matters, including those involving crypto, to protect American retail investors. We ask that the SEC request that the Court lift the stay and that the SEC litigate the case consistent with the facts alleged in its complaint. Alternatively, should the SEC determine that a settlement would be the best outcome for harmed investors, we ask that such a settlement reflect the strength of the SEC’s case and be consistent with the relief it would have obtained had it litigated the case to a favorable judgment. The SEC’s Strong Case Against Justin Sun The SEC’s complaint, filed on March 22, 2023, alleged unlawful conduct spanning several years. The SEC alleged that Sun “engineered the offer and sale of two crypto asset securities called ‘TRX’ and ‘BTT’” to the investing public starting in 2017, but never filed a registration statement for these offerings.20 Sun’s conduct, however, extended beyond registration violations to securities fraud. As the SEC detailed in its complaint, “Sun directed the manipulative wash trading of TRX to create the artificial appearance of legitimate investor interest and keep TRX’s price afloat.”21 Under Sun’s direction, the SEC alleged, employees conducted “hundreds of thousands of TRX wash trades” between accounts that Sun ultimately controlled, with no change in beneficial ownership of the tokens and “no legitimate economic purpose.”22 The SEC claimed that these manipulative trading activities generated a false impression of a liquid market, allowing Sun to sell approximately $31 million worth of tokens to unsuspecting investors.23 The SEC’s complaint also alleged that the scheme was made worse by Sun’s orchestration of an unlawful celebrity promotion campaign.24 The SEC detailed allegations that Sun paid multiple celebrities (who had millions of online followers) to promote TRX and BTT on social media “without disclosing that they had been paid.”25 According to the SEC’s complaint, Sun publicly lied about these arrangements, falsely claiming on Twitter in February 2021 that, “If any celebrities are paid to promote TRON, we require them to disclose,” even as “Sun himself arranged the payments to celebrities and knew those payments were not disclosed.”26

Chair Atkins has suggested that the crypto cases his agency has dropped were merely over "registration issues" that were "red herrings" from the Biden admin. But the complaint against Sun also alleged serious fraud.

The Commission also alleges that Sun violated the antifraud and market manipulation provisions of the federal securities laws by orchestrating a scheme to artificially inflate the apparent trading volume of TRX in the secondary market. From at least April 2018 through February 2019, Sun allegedly directed his employees to engage in more than 600,000 wash trades of TRX between two crypto asset trading platform accounts he controlled, with between 4.5 million and 7.4 million TRX wash traded daily. This scheme required a significant supply of TRX, which Sun allegedly provided. As alleged, Sun also sold TRX into the secondary market, generating proceeds of $31 million from illegal, unregistered offers and sales of the token. “This case demonstrates again the high risk investors face when crypto asset securities are offered and sold without proper disclosure,” said SEC Chair Gary Gensler. “As alleged, Sun and his companies not only targeted U.S. investors in their unregistered offers and sales, generating millions in illegal proceeds at the expense of investors, but they also coordinated wash trading on an unregistered trading platform to create the misleading appearance of active trading in TRX. Sun further induced investors to purchase TRX and BTT by orchestrating a promotional campaign in which he and his celebrity promoters hid the fact that the celebrities were paid for their tweets.”

In July, shortly after Sun announced his plan to purchase another $100 million of the $TRUMP memecoin, the Sun-involved and -themed SUNDOG memecoin posted a meme showing its corgi mascot holding puppet strings attached to the White House.