OCC Corporate Decision #1381 — Wise National Trust Denial
July 21, 2026 — Stephen A. Lybarger, Senior Deputy Comptroller
OCC denies Application to charter Wise National Trust, Austin, Texas (Control No. 2025-Charter-342106). Reasons: significant supervisory and compliance concerns under 12 CFR 5.13(b) / 5.20.
Key facts cited:
- July 9, 2025 Multistate Consent Order on Wise US AML/CFT deficiencies; $4.2M administrative penalty; California DFPI separate order.
- Deficiencies: SAR investigation/reporting, transaction monitoring data integrity, independent review frequency, delayed remediation.
- Organizers lacked sufficient familiarity with federal banking/fiduciary rules (12 CFR 9).
- Proposed management/board competence concerns for fiduciary + AML/CFT.
- Denial does not prohibit future reapplication; subsequent application must address reasons for denial.