OCC rejects Wise’s trust charter application over ‘deficiencies’

The British fintech said it plans to submit a new application for a U.S. trust charter under a Genius Act framework.

Dive Brief:

• The Office of the Comptroller of the Currency has denied London-based Wise’s application to establish a national trust bank.
• In a Tuesday letter, Stephen Lybarger, the OCC’s senior deputy comptroller for chartering, organization and structure, said Wise’s application “presents significant supervisory and compliance concerns.” He pointed to state regulatory actions taken against Wise related to anti-money laundering compliance and that organizers didn’t demonstrate “sufficient familiarity” with federal banking laws and regulations.
• Wise plans to submit a new application to the OCC for a national trust bank charter under a Genius Act framework, the company said in a Thursday filing.

Dive Insight:

In July 2025, less than a month after submitting its application to the OCC, the company’s U.S. arm was hit with a multi-state consent order over deficiencies in its Bank Secrecy Act, anti-money laundering and countering the financing of terrorism programs.

Wise US agreed to pay $4.2 million and boost its compliance investments as part of the order. California regulators also issued their own consent order with Wise US.

Lybarger noted “significant enforcement actions such as these are important to, but do not ultimately control,” the OCC’s application decisions. The denial appears to be the first from the OCC amid the current influx of charter applications during the second Trump administration.

The OCC determined the proposed trust bank’s AML/CFT compliance would be lacking “until Wise has addressed existing deficiencies and develops an enhanced enterprise-wide AML/CFT program.” Wise US has a record of compliance failure with money services businesses requirements, and the application “does not support a conclusion” that it will meet added AML/CFT requirements for trust banks.

Lybarger criticized proposed leadership: organizers are “part of long-standing AML/CFT deficiencies at Wise US,” which “has been in continuing noncompliance” with federal AML/CFT requirements; organizers “failed to select appropriate directors and management officials with sufficient experience” with AML/CFT and fiduciary activities. Wise US has “no historical experience with fiduciary activities.”

The denial doesn’t preclude a future application if deficiencies are addressed. Wise said Thursday its compliance maturity has evolved significantly and it looks forward to submitting a viable application. William Blair analyst Cristopher Kennedy noted about one-third of Wise’s workforce is focused on financial crime prevention.

Wise also said its original application approach became “non-viable” after a Federal Reserve master-account change proposed in May, and it sees new opportunities under the GENIUS Act for stablecoin/payment-rail interoperability.