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XWELL, the Trump sons and $38.8 million in public commitments

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dated revision: November 10, 2026primary sourcesno tracker
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XpresTest has secured $38.8 million in federal commitments for health programmes. Its parent XWELL was financed by a vehicle connected to Dominari, a company in which Donald Trump Jr. and Eric Trump own shares. Official records and securities filings identify the financial interests, compensation and proposed sale of the operating businesses.

Documentary investigation checked through 10 November 2026. Scope: the United States and a health programme in the Democratic Republic of Congo. All monetary amounts are nominal US dollars.

For years, XWELL’s airport business meant massages and wellness treatments. Its subsidiary XpresTest also does something very different: collecting samples to monitor infectious diseases among travellers. That health business now sits at the intersection of a private financing deal, federal awards and a proposed change of ownership.

Official records show $38,815,410.68 in federal obligations to XpresTest, across a contract from the Centers for Disease Control and Prevention, or CDC, and a State Department cooperative agreement. The contract covers a year; the cooperative agreement runs for two. Their sum measures cumulative commitments across different missions. The outlay fields in the retrieved records are unreported. S26 S29

XpresTest is the recipient of the awards. The Trump brothers’ connections run through the financing of its parent, XWELL. Donald Trump Jr. and Eric Trump own shares in Dominari, whose entities arrange the placement or manage investment vehicles. Assessing the conflict-of-interest risk requires following those relationships through to the decisions and gains that the evidence actually establishes. S12 S15 S28

Two federal awards with different health missions

CDC contract 75D30126C21193 concerns Ebola entry-screening services. The official notice gives an award date of 6 July 2026, followed by publication on 28 July. USAspending’s transaction history shows $18,137,975 obligated on 6 July, with a further $677,435.68 on 25 September. The resulting total is $18,815,410.68, for performance running through 5 July 2027. Today’s $18.8 million figure therefore includes an addition made after the initial award. S01 S26

The State Department award is cooperative agreement SAQMMA26CA0383. Official transactions record $20 million obligated on 25 September 2026, with performance from 28 September 2026 to 30 September 2028 and a place of performance in the Democratic Republic of Congo. This is federal assistance. Treating it as another procurement contract would erase differences in the instruments’ purpose and oversight. S29

An obligation commits government resources to an award. Payment depends on performance; recognised revenue follows accounting rules; profit reflects costs. The records establish the commitments. Actual disbursements and the profitability of each assignment require additional evidence. An unreported outlay field remains missing data. S26 S29

Choosing a supplier under emergency conditions

The CDC record identifies a non-competed procurement, one offer and an urgency justification. The official notice describes Ebola response and a sole-source acquisition. The important questions concern the reasons for selecting the supplier: readiness, alternatives considered, negotiated pricing and supervision of delivery. S01 S26

Federal acquisition rules provide an exception for unusual and compelling urgency, alongside justification requirements and an obligation to request offers from as many sources as circumstances permit. The notice refers to both the traditional numbering and the acquisition-rule overhaul. Evaluating the procurement requires the applicable rules and, above all, the signed justification for this particular award. HHS had aligned its acquisition supplement with the overhaul through a deviation signed on 21 November 2025, effective immediately for the covered actions. This provides context for the dual numbering; the signed award-specific justification remains unavailable. S04 S05 S30

XpresTest had a health business before American Ventures financed XWELL. In January 2026, the CDC said its traveller genomic-surveillance programme, launched in 2021, involved a partnership with XWELL and Ginkgo. The agency reported more than one million participants across the whole programme. That operating history provides a concrete basis for examining the supplier’s capabilities and the resources required by a new assignment. S06

On 8 January, XWELL also announced that Cindy Friedman, formerly a CDC official and leader of its traveller-surveillance programme, would become a biosecurity adviser. Her background brings directly relevant expertise. The release leaves her possible role in the July procurement unspecified; the ethics records governing any contacts with her former agency remain to be established. S07

The parent company was financially vulnerable. For 2025, XWELL reported $29.2 million in revenue and approximately $17 million in net loss attributable to the company. Year-end cash and equivalents were $2.6 million, excluding restricted funds. Those figures explain the importance of fresh financing and a reorganisation of the businesses. S08 S27

The Trump brothers’ interests run through Dominari

Dominari’s proxy filed on 6 November 2026 provides an ownership snapshot dated 20 October. Donald Trump Jr. and Eric Trump each held 1,398,414 shares, or 5.55% of common stock on the published denominator of 25,201,979 shares. September filings gave 5.77% using another denominator. The reported share count for each brother is unchanged between those records. S13 S14 S28

Several functions sit below Dominari. The group reports owning 90% of American Ventures Management and American Ventures IM, which are management entities. American Ventures Series XXIV holds the investment in XWELL and appears as a direct holder of its securities. Dominari Securities separately acts as the compensated placement agent. S09 S12 S15

The structure creates different potential sources of return: placement services, management rights and the value of securities held by investors. The series’ private agreements would be needed to explain how those returns are allocated. We did not obtain those agreements, a complete investor register or records documenting any realised personal gains. Multiplying 5.55% by 90% and applying the result to federal awards would combine different interests and rights.

The Trump brothers deny intervening in awards, ProPublica reports. S25 Our primary-source collection establishes the financial relationships described here; communications capable of demonstrating intervention in the award process remain to be obtained.

The economic links between the Trumps, Dominari and XWELL Donald Trump Jr. and Eric Trump each report 1,398,414 Dominari shares,5.55% of 25,201,979 shares as of October 20, 2026. Dominari owns 90% of each of American Ventures Management and IM. Series XXIV directly holds XWELL securities; management does not determine investors’ economic interests. Dominari Securities is the placement agent. Arrows are qualitative relationships, with no allocation of personal gains or multiplication of stakes. TRUMP, DOMINARI AND XWELL FINANCING Brothers’ Dominari holdings: October 20, 2026 Donald Trump Jr. 1,398,414 shares 5.55% Eric Trump 1,398,414 shares 5.55% Dominari Holdings Listed holding company 90% of each manager American Ventures Management LLC + IM LLC Dominari Securities Placement agent Management Paid placement American Ventures Series XXIV XWELL XWELL Securities Series XXIV: investor economics remain to be established. Arrows are qualitative.
The economic links between the Trumps, Dominari and XWELL Donald Trump Jr. and Eric Trump each report 1,398,414 Dominari shares,5.55% of 25,201,979 shares as of October 20, 2026. Dominari owns 90% of each of American Ventures Management and IM. Series XXIV directly holds XWELL securities; management does not determine investors’ economic interests. Dominari Securities is the placement agent. Arrows are qualitative relationships, with no allocation of personal gains or multiplication of stakes. TRUMP, DOMINARI AND XWELL Dominari shares: October 20, 2026 Donald Trump Jr. 1,398,414 shares 5.55% Eric Trump 1,398,414 shares 5.55% Dominari Holdings 90% Group American Ventures Management / IM Dominari Securities Placement Management Series XXIV XWELL XWELL Series XXIV: investor economics remain to be established. Arrows = qualitative relationships.
FIGURE 01Ownership and roles in XWELL’s financingDominari snapshot at October 20, 2026, published in the November 6 proxy: Donald Trump Jr. and Eric Trump each hold 1,398,414 shares, or 5.55% of 25,201,979 common shares. In its report at June 30, 2026, Dominari owns 90% of each of American Ventures Management LLC and American Ventures IM LLC. Arrows represent qualitative relationships, without a monetary scale. [S09][S12][S15][S28]
Method and scope
The personal percentages are measured within Dominari’s common equity: 1,398,414 / 25,201,979 × 100 = 5.548826...%, rounded to 5.55%. The snapshot is October 20, 2026; the filing is November 6. The 90% applies to the two management companies identified in Dominari’s June 30, 2026 10-Q, rather than investors’ economic rights in Series XXIV. That series directly holds XWELL securities; the managers and Dominari report voting and dispositive powers. The group distinguishes management functions from the paid placement role of Dominari Securities. The complete investor register, series distributions and the brothers’ personal gains remain to be established. The graph does not support multiplying the percentages through to XWELL and traces no public-funds payment to the family.

Fees, refinancing and the cash left for XWELL

The February placement raised $31.333 million gross in two closings: $30.832 million on 27 February and $501,000 on 3 March. It combined convertible preferred shares with warrants, instruments giving their holders the right to obtain shares on specified terms. S09 S10

Dominari Securities’ compensation terms included a cash fee of 8% of funds raised, a 1% expense allowance and placement-agent warrants. Applied to the actual gross proceeds, the first two components amount to approximately $2.507 million and $313,330. They concern the intermediary. Establishing any amount personally received by a shareholder would require separate evidence. S09 S10

The first-half cash-flow statement reports $28.269 million net proceeds. The $3.064 million difference from gross proceeds measures cash financing costs deducted from the funds raised. The 10-Q reports a higher accounting cost of issuance, $10.216 million, including $7.152 million in the fair value of placement-agent warrants. That non-cash component explains the difference. The cash reconciliation includes only financing costs actually deducted from proceeds. S11

Of the net cash, $9 million redeemed earlier instruments. That leaves a subtotal of $19.269 million before other cash flows. The company’s operations and other transactions must then be included to assess its position. At 30 June, cash including restricted funds stood at $12.346 million; operating activities had used $9.117 million during the first half. S11

A headline financing amount can therefore support the business while paying intermediaries and allowing earlier capital providers to exit. That allocation matters when assessing each participant’s incentives and the resources available for the operating business.

XWELL financing, from gross proceeds to available funds February and March 2026 placement, nominal dollars. Gross proceeds of 31.333 million less 3.064 million of cash financing costs give 28.269 million net.9 million redeems earlier instruments, leaving 19.269 million before other cash flows. Accounting costs of 10.216 million include 7.152 million of warrant fair value without an immediate cash outflow and must not be subtracted again from gross cash proceeds. AVAILABLE CASH AFTER THE FINANCING February–March 2026 · US$ million 0 31.333 −3.064 −9 19.269 Gross proceeds Cash financing costs Earlier instrument redemptions Before other cash flows Common scale. Net proceeds after cash financing costs are $28.269 million.
XWELL financing, from gross proceeds to available funds February and March 2026 placement, nominal dollars. Gross proceeds of 31.333 million less 3.064 million of cash financing costs give 28.269 million net.9 million redeems earlier instruments, leaving 19.269 million before other cash flows. Accounting costs of 10.216 million include 7.152 million of warrant fair value without an immediate cash outflow and must not be subtracted again from gross cash proceeds. AVAILABLE CASH AFTER THE FINANCING February–March 2026 · US$ million 31.333 gross 28.269 net 19.269 before other cash flows −3.064 cash financing costs Placement and paid expenses −9 to redeem earlier instruments Redemption of financing securities Operations, investment and other flows enter the cash balance separately. All three bars share the same scale.
FIGURE 02From gross proceeds to available cashNominal dollars, February–March 2026 placement: 31.333 million gross, 3.064 million of cash financing costs, then 9 million redeeming earlier instruments. The 19.269 million remainder precedes the company’s other cash flows. Net proceeds after cash costs are 28.269 million. [S10][S11]
Method and scope
Cash calculation: 31,333,000 − 3,064,000 = 28,269,000 dollars; 28,269,000 − 9,000,000 = 19,269,000 dollars before other cash flows. Cash financing costs are the difference between closed gross proceeds and net issuance proceeds in the cash-flow statement. They differ from the 10,216,000 dollars of accounting transaction costs in note 10 of the 10-Q: that amount includes 7,152,000 dollars of warrant fair value without an immediate cash outflow. The reconciliation is 3,064,000 + 7,152,000 = 10,216,000; subtracting 10,216,000 from gross cash proceeds would double count. The 8% placement fee and 1% expense allowance are not deducted a second time in this bridge. Operations, investment and other movements enter the final cash balance; 19.269 million is not closing cash. Bar dimensions are proportional to dollars on a common scale within each variant.

The $13 million offer arrived in March

On 6 July 2026, the date of the CDC’s initial award, XWELL signed an agreement to sell XpresTest and XpresSpa to Express Wellness Group, an entity affiliated with Face Haus. The $13 million base price is subject to adjustments. It covers two businesses, with XWELL as the seller. S17 S18

The coincidence deserves scrutiny. The negotiation history given to shareholders adds an important earlier date: Face Haus submitted a non-binding $13 million offer on 11 March, followed by an exclusivity agreement on 17 March. Discussions had started in August 2025. S16

That sequence changes the investigation. Establishing the health business’s influence on price would require comparing forecasts, risks and information exchanged in the spring with those available in July. An unchanged base price can coexist with different commercial assumptions or adjustments. The public record supplies the chronology and some assumptions; the complete communications between the parties remain unavailable.

The buyer would acquire the subsidiaries’ equity. A share acquisition can preserve the legal entity performing an existing contract. Federal rules provide for certain stock acquisitions in which a novation agreement is unnecessary. The particular contract’s obligations and any required agency arrangements still need to be checked against the applicable records. S22

Existing cash explains Roth’s $30.1 million valuation

Roth’s model uses a financial snapshot dated 31 March 2026. It adds a $13 million base price to $17.1 million of existing cash: $15.6 million would be distributed before closing, while $1.5 million would remain in the subsidiaries and enter the price adjustment. The result is $30.1 million of value in that model. Recovering money already held within the group preserves existing wealth; it does not create another premium paid by the buyer. S16 S18

The agreement also provides for $2.65 million in escrow at closing: $750,000 for adjustments, $1.65 million for indemnification and $250,000 for litigation. The final proceeds depend on cash, debt, unpaid transaction expenses and working capital, the resources tied up in day-to-day operations. The announced price can therefore differ from the cash immediately available to the seller. S18

A financial fairness opinion addresses a question for the seller and its shareholders. A public supplier’s selection requires a separate examination, with its own documents and decision-makers. Each assessment has to remain within its remit.

The Roth model: base price and existing cash A valuation model, not a closing statement.13 million dollars of base price,15.6 million of assumed pre-closing distribution and 1.5 million of remaining cash give 30.1 million. The 17.1 million existing cash is dated March 31, 2026. Escrows of 2.65 million are provided for at closing, and RSA repurchases already paid in October are excluded from unpaid sale expenses. PRICE AND CASH IN THE MODEL Roth · cash snapshot at March 31, 2026 $30.1 million modelled value 13.0 15.6 1.5 Base price: $13.0 million $17.1 million of existing cash 15.6: assumed pre-closing distribution 1.5: cash left in subsidiaries, credited in price The model combines the base price with cash already held by the group. Closing: contractual adjustments and $2.65 million of planned escrows. Roth model values, distinct from a completed payment. Completion remains unconfirmed.
The Roth model: base price and existing cash A valuation model, not a closing statement.13 million dollars of base price,15.6 million of assumed pre-closing distribution and 1.5 million of remaining cash give 30.1 million. The 17.1 million existing cash is dated March 31, 2026. Escrows of 2.65 million are provided for at closing, and RSA repurchases already paid in October are excluded from unpaid sale expenses. PRICE AND CASH IN THE MODEL Roth · cash at March 31, 2026 $30.1 million modelled value 13.0 15.6 1.5 Base price $17.1 million Existing cash 15.6: assumed distribution before closing. 1.5: cash left in the subsidiaries, included in the price adjustment. Closing: contractual adjustments and planned escrows of $2.65 million. Actual completion remains unconfirmed.
FIGURE 03Price and existing cash in the Roth modelThe Roth model uses cash at March 31, 2026: 13 million base price + 15.6 million assumed pre-closing distribution + 1.5 million left in the subsidiaries = 30.1 million of value. The two cash components total 17.1 million already held. Escrows of 2.65 million are provided for at closing, together with contractual adjustments. Completion of the sale remains unconfirmed. [S16][S18][S19]
Method and scope
Nominal amounts in the shareholder model, based on management assumptions. Calculation: 13 + 15.6 + 1.5 = 30.1 million dollars; 15.6 + 1.5 = 17.1 million of existing cash at March 31. The initial 13 million proposal was non-binding on March 11; the definitive agreement was signed on July 6 and shareholders approved it on October 28. Those events do not establish completion. Contractual escrows of 2.65 million consist of 750,000 dollars for adjustments, 1,650,000 for indemnities and 250,000 for an arbitration matter. The final price depends on cash, debt, unpaid sale expenses and working capital. RSA repurchases reported as paid in October are excluded from unpaid expenses, without a second deduction. The discrepancy between October 5 in the proxy and October 8 in the 8-K remains unresolved. The model rounds escrow to 2.7 million and net value to 27.4 million; the displayed rounded inputs cannot yield an exact final value. Graph widths are proportional to model components, rather than cash actually received.

Executives received cash ahead of the proposed sale

A personal cash flow was reported in October. XpresTest repurchased 279.5 securities awarded to executives, former employees or service providers as share-based compensation for approximately $2.7 million. The 8-K states that unvested rights were accelerated and that a payment originally due at the sale was brought forward with the buyer’s agreement. Bruce Bernstein received approximately $1.031 million, Ezra Ernst $530,000 and Ian Brown $96,000. S19

Those payments raise concrete questions about award dates, valuation and recipients’ involvement in decisions. A payment can follow contractual rights while influencing the options a recipient has an incentive to favour. The proxy dates the repurchase to 5 October; the 8-K gives 8 October. We preserve that discrepancy. The bank-level origin of the funds and any connection to CDC disbursements remain unknown. S18 S19

The economic treatment must also respect the timing. Money already paid belongs to earlier cash flows; deducting it again as an unpaid disposal expense would distort the calculation of sale proceeds.

Financing instruments become part of the vote

The convertibles include a 4.99% beneficial-ownership blocker, which can be raised to 9.99% after notice. This limits an ordinary-share position at a given moment. Economic exposure also depends on conversions, remaining warrants and any sales actually made. Calculating a return would require those transactions and their realised prices. S09 S15

Series XXIV describes notice on 7 July, effectiveness on 7 September and a conversion on 8 September yielding 993,617 common shares. The proxy supplement links the increase and conversion to a support agreement with the buyer dated 6 July. The series agreed, among other things, to support the sale and oppose certain alternatives. The financing thus connects directly to transaction governance through a documented agreement. S15 S20

The company subsequently corrected the voting-share denominator after omitting 650,000 shares awarded to directors. The count rose from 9,970,883 to 10,620,883. Holding the series’ 993,617-share numerator constant changes the calculated proportion from 9.97% to 9.36%. That movement reflects the denominator rather than a newly observed disposal of shares. S15 S20

On 28 October, the proposal received 5,423,862 votes in favour, or 51.07% of eligible shares. Shareholder approval is one step towards completion. The SEC submissions register reviewed on 10 November lists XWELL’s latest filing as the 29 October 8-K reporting the vote. Our collection obtained no subsequent public confirmation of closing. Completion therefore remains to be confirmed. S21

Transparency must follow the financial interests

The records go beyond a coincidence of famous names and large numbers. Dominari receives placement compensation; a vehicle holds securities and commits to support a sale; executives receive an early payment; XpresTest obtains two federal awards. The family connections to the president make scrutiny of those decisions and their beneficiaries particularly important.

Oversight of the CDC procurement should make the urgency justification, alternatives and price analysis examinable. Oversight of the cooperative agreement must address performance obligations and supervision of the funds. For the sale, the forecasts used in the spring and July, followed by the closing statement, would help connect commercial expectations with the amounts ultimately realised.

This investigation documents financial interests and public decisions. Establishing preferential treatment would require examining selection against alternatives and applicable rules, then documenting any improper advantage and its beneficiaries. Correspondence or interventions could help establish how the decisions were made. That evidentiary standard strengthens the case for transparency now, while decisions are committing public money.

Method and limitations

The financial facts rest on SEC filings and company documents, with their statements explicitly attributed. Official USAspending award records and transaction histories were reviewed on 10 November for both federal awards. Their obligations are added cumulatively across different instruments and performance periods. Outlays remain unreported. Calculations are explained in the text and the figure methods.

We did not obtain bank records, the series’ complete investor list, the signed procurement justification or a final closing statement. No requests for comment were sent. The opening illustration was generated with the built-in image tool; the analytical graphics use the cited records and calculations.

Further reading

Our investigation of public investment in Intel and MP Materials examines taxpayer risks through the contracts and securities involved. The analysis of Trump Jr., drones and Unusual Machines distinguishes holdings, financial instruments and links to industrial policy.

Sources and scope

  1. S01 · CDC / SAM.gov · Accessed: 2026-11-10Ebola Entry Screening Services • JOFOC_75D30126C21193
    Passages and scope

    2026-07-28

    Original CDC notice read in full. Award on 6 July, notice on 28 July; sole-source urgency procurement. The signed justification attachment was not obtained.

  2. S04 · Acquisition.gov · Accessed: 2026-11-10FAR 6.302-2 • Unusual and compelling urgency
    Passages and scope

    Publication date not established

    Traditional FAR urgency exception. The general rule does not resolve the legality or pricing of this particular procurement.

  3. S05 · Acquisition.gov · Accessed: 2026-11-10FAR overhaul • Part 6, Competition requirements
    Passages and scope

    Publication date not established

    Overhauled Part 6, including RFO 6.103-2. Read with HHS’s published deviation and the original CDC notice.

  4. S06 · CDC · Accessed: 2026-11-10CDC surpasses 1 million voluntary air travel participants
    Passages and scope

    2026-01-30

    CDC report for the entire traveller-surveillance programme, launched in 2021. One million participants cannot be assigned to XWELL alone.

  5. S07 · XWELL · Accessed: 2026-11-10XWELL appoints former CDC expert as biosecurity adviser
    Passages and scope

    2026-01-08

    Issuer announcement of Cindy Friedman’s appointment. Her role in the July award and relevant ethics records were not established.

  6. S08 · XWELL · Accessed: 2026-11-10XWELL reports fiscal 2025 results
    Passages and scope

    2026-04-01

    Issuer-reported 2025 revenue, attributable loss and unrestricted cash. Cross-checked with the annual filing.

  7. S09 · XWELL / SEC EDGAR · Accessed: 2026-11-10Form 8-K • Private placement terms
    Passages and scope

    2026-02-25

    Preferred securities, warrants, ownership blockers and placement-agent terms. Compensation of an intermediary is distinct from a shareholder’s personal receipts.

  8. S10 · XWELL / SEC EDGAR · Accessed: 2026-11-10Form 8-K • Closing of private placement
    Passages and scope

    2026-03-04

    Two placement closings, actual gross proceeds of $31.333 million and redemption of earlier instruments.

  9. S11 · XWELL / SEC EDGAR · Accessed: 2026-11-10Form 10-Q • Quarter ended June 30, 2026
    Passages and scope

    2026-08-14

    First-half cash-flow statement and Note 9: $3.064 million cash financing costs, $7.152 million warrant fair value and $10.216 million accounting issuance costs. Net proceeds and ending cash have different scopes.

  10. S12 · Dominari / SEC EDGAR · Accessed: 2026-11-10Form 10-Q • American Ventures management structure
    Passages and scope

    2026-08-11

    Ownership of 90% of two American Ventures management entities. The filing distinguishes management from investors’ rights in individual series.

  11. S13 · SEC EDGAR · Accessed: 2026-11-10Schedule 13G • Donald J. Trump Jr.
    Passages and scope

    2026-09-16

    Donald Trump Jr.’s historical September filing: 1,398,414 shares and 5.77% using the stated denominator. The newer snapshot is S28.

  12. S14 · SEC EDGAR · Accessed: 2026-11-10Schedule 13G • Eric Trump
    Passages and scope

    2026-09-16

    Eric Trump’s historical September filing: 1,398,414 shares and 5.77% using the stated denominator. The newer snapshot is S28.

  13. S15 · SEC EDGAR · Accessed: 2026-11-10Schedule 13D amendment • American Ventures Series XXIV
    Passages and scope

    2026-09-08

    Series XXIV holdings, notice and conversion dates, ownership limitations and separate securities. No realised personal gain is calculated.

  14. S16 · XWELL / SEC EDGAR · Accessed: 2026-11-10Preliminary proxy • Background of the sale and Roth opinion
    Passages and scope

    2026-07-27

    Negotiation history, non-binding 11 March offer, exclusivity and Roth’s model using 31 March cash. Valuation model and realised sale proceeds are distinct.

  15. S17 · XWELL · Accessed: 2026-11-10Definitive agreement to divest XpresSpa and XpresTest
    Passages and scope

    2026-07-07

    Issuer announcement of the proposed two-business sale, $13 million base price and intended strategic direction. Announcement is distinct from closing.

  16. S18 · XWELL / SEC EDGAR · Accessed: 2026-11-10Definitive proxy • Sale proposal
    Passages and scope

    2026-10-08

    Definitive proxy, transaction adjustments, escrows, management interests and conditions. The proxy’s 5 October repurchase date differs from S19.

  17. S19 · XWELL / SEC EDGAR · Accessed: 2026-11-10Form 8-K • XpresTest restricted stock repurchases
    Passages and scope

    2026-10-08

    Repurchase of 279.5 restricted securities, acceleration and early cash payments. The filing gives 8 October; rounded total approximately $2.7 million.

  18. S20 · XWELL / SEC EDGAR · Accessed: 2026-11-10Proxy supplement • Correction of outstanding shares
    Passages and scope

    2026-10-21

    Corrected eligible-share count, omitted director awards and the support agreement linking the ownership-blocker increase and conversion to voting commitments.

  19. S21 · XWELL / SEC EDGAR · Accessed: 2026-11-10Form 8-K • Special meeting voting results
    Passages and scope

    2026-10-29

    Voting results for 28 October. The live SEC submissions register was also read on 10 November: latest listed XWELL filing dated 29 October. No subsequent closing confirmation was obtained.

    SEC submissions register

  20. S22 · Acquisition.gov · Accessed: 2026-11-10FAR 42.1204 • Applicability of novation agreements
    Passages and scope

    Publication date not established

    Novation rules and some share acquisitions preserving the contracting legal entity. No agency determination for this particular proposed sale was obtained.

  21. S25 · ProPublica · Accessed: 2026-11-10Response
    Passages and scope

    2026-11-09

    Reported response; no interview was conducted by l0g.

  22. S26 · USAspending.gov · Accessed: 2026-11-10USAspending: CDC contract 75D30126C21193
    Passages and scope

    Publication date not established

    Official award and complete transaction history: initial $18,137,975, addition $677,435.68, cumulative obligations $18,815,410.68. One-year contract, one offer, sole-source urgency. Outlays unreported, not established as zero.

    Official JSON record

  23. S27 · XWELL / SEC EDGAR · Accessed: 2026-11-10Form 10-K • Year ended December 31, 2025
    Passages and scope

    2026-04-01

    Annual accounts: cash $2.617 million and net loss attributable to XWELL $16.991 million. Consolidated loss and loss attributable to common shareholders are different measures.

  24. S28 · Dominari Holdings / SEC EDGAR · Accessed: 2026-11-10Dominari proxy: beneficial ownership at 20 October 2026
    Passages and scope

    2026-11-06

    Proxy filed 6 November, snapshot 20 October: each brother holds 1,398,414 common shares, 5.55% of 25,201,979. No personal interest or realised return in each investment series is established.

  25. S29 · USAspending.gov / Department of State · Accessed: 2026-11-10USAspending: State cooperative agreement SAQMMA26CA0383
    Passages and scope

    Publication date not established

    Official cooperative-agreement record and complete transaction history: $20 million obligated on 25 September; performance 28 September 2026 to 30 September 2028, Congo (Kinshasa). Federal assistance; procurement competition codes from the CDC award do not apply. Outlays unreported.

    Official JSON record

  26. S30 · Department of Health and Human Services · Accessed: 2026-11-10HHSAR Class Deviation 2026-01
    Passages and scope

    2025-11-21

    HHSAR Class Deviation 2026-01, signed and effective 21 November 2025: alignment of Part 306 and other specified provisions with the overhaul. Context for rule numbering; not a complete legal assessment of the award.

This analysis is not investment advice.

// cite this analysis

l0g, “XWELL, the Trump sons and $38.8 million in public commitments”, l0g.fr, published November 10, 2026, updated November 10, 2026, https://l0g.fr/en/analysis/xwell-trump-sons-public-money/


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