The Office of the Comptroller of the Currency has denied Wise’s application to establish a U.S. national trust bank, concluding that the proposal presented significant supervisory and compliance concerns.
The July 21 decision connects a licensing outcome directly to weaknesses identified in Wise US’s anti-money laundering and counter-terrorist financing controls. It also criticizes the experience of the proposed bank’s organizers, management and board. The OCC said the application did not demonstrate that the institution would operate in compliance with applicable laws and regulations.
The denial is not an order to stop Wise’s existing U.S. money-transfer business. Wise said its normal operations remain unaffected under its money transmitter licenses and that it intends to submit a new trust-charter application. But the decision blocks the particular structure the company proposed and establishes a detailed remediation test for any renewed bid.
What Wise wanted the trust bank to do
Wise proposed Wise National Trust in Austin, Texas, as a nondepository national trust bank. According to the OCC decision, the bank would have offered stored-value multi-currency accounts with debit cards to U.S. customers, processed payments for direct customers, Wise affiliates and third parties, and provided fiduciary services.
The proposed bank was intended to make Wise’s U.S. payments program more efficient and scalable. Wise currently uses numerous correspondent-banking relationships, while the trust-bank model contemplated possible access to a Federal Reserve master account.
That structure made the quality of the wider Wise control environment central to the charter review. The proposed bank expected to rely significantly on Wise US and other global affiliates for AML compliance. The OCC therefore assessed the sponsor’s enterprise-wide record rather than treating the planned bank as a clean new entity.
The compliance record behind the denial
In July 2025, less than a month after the charter application was filed, Wise US entered a multistate consent order over deficiencies in its Bank Secrecy Act and AML/CFT program. The order identified problems involving suspicious-activity investigation and reporting, transaction-monitoring data integrity, late suspicious activity reports, the frequency of independent program reviews and delays in correcting earlier findings. Wise US agreed to pay a $4.2 million administrative penalty shared among participating regulators. California issued a separate order addressing state-specific requirements.
The OCC said those enforcement actions were important but did not automatically determine the charter decision. Its denial also relied on its own review of the proposed compliance program, information from U.S. and other regulators, and the application record.
Based on that evidence, the agency said it could not conclude that the proposed bank would have an effective U.S. AML/CFT program until Wise addressed existing deficiencies and developed an enhanced enterprise-wide program. It found that the application did not adequately address key weaknesses in the proposed risk-management framework.
The OCC also emphasized the regulatory step-up involved. Wise US operates as a money services business, while a national trust bank would face additional federal bank AML requirements. The agency said Wise US’s record of noncompliance with requirements already applicable to money services businesses did not support a conclusion that the proposed bank could meet the added obligations.
Management and board experience also failed the test
The decision goes beyond technical control design. The OCC found that the organizers did not demonstrate sufficient familiarity with national banking laws and regulations and criticized their selection of directors and management officials.
According to the agency, proposed management and directors did not demonstrate sufficient competence in either bank-level AML/CFT obligations or the rules governing fiduciary activities. It noted that Wise US had no historical experience with fiduciary activities and said the proposed leadership did not show adequate relevant experience.
The OCC described the proposed services as carrying high inherent money-laundering, terrorist-financing and other illicit-finance risks. It said the proposed leadership had demonstrated a persistent inability to manage those risks sufficiently. Those are the regulator’s findings in a licensing decision, not a finding that the proposed bank committed misconduct; the bank was never chartered.
Wise says its controls have matured
Wise said in a July 23 regulatory filing that its business and compliance maturity had evolved significantly since the original application was prepared. The company said it had strengthened its U.S. program, improved investigation and reporting processes, improved customer-data integrity and increased compliance resources in response to the 2025 consent order.
Wise also said the original structure had become non-viable after a proposed Federal Reserve policy change in May 2026 because the application depended on direct master-account access. The company plans to submit a new national trust bank application under a framework connected to the GENIUS Act, while maintaining its existing relationship with the OCC.
The OCC left that route open. Its decision does not prohibit a new application, but the agency said any subsequent filing would be expected to address the reasons for the denial and satisfy the applicable chartering factors.
Why this matters for payments firms
The decision shows that a charter application is an enterprise-control test, not merely a review of a proposed legal entity. Where a new bank would depend on an affiliated payments platform, regulators can examine the affiliate’s transaction monitoring, reporting, remediation history, governance and management depth as part of the bank application.
For fintechs pursuing bank status, the practical lesson is that licensing strategy cannot run ahead of demonstrable control maturity. A larger compliance budget or a rewritten policy may not be enough if data integrity, suspicious-activity processes, repeat findings and board expertise remain unresolved.
Wise’s next application will provide a measurable test of its response. The key questions will be whether it can show completed remediation across the enterprise, appoint leadership with bank and fiduciary experience, and propose an operating model that does not depend on uncertain payment-system access. Until then, the denial preserves Wise’s existing U.S. business but prevents the company from gaining the federal trust-bank structure it sought.