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Wise is preparing a second attempt to secure a U.S. national trust bank charter after the Office of the Comptroller of the Currency (OCC) rejected its initial application, citing significant shortcomings in the company’s anti-money laundering and compliance framework.
OCC rejects Wise’s US Bank Charter application
While the decision represents a setback for the London-headquartered cross-border payments specialist, Wise insists it has already addressed many of the concerns raised and intends to submit a new application aligned with the evolving U.S. regulatory landscape, including the recently enacted GENIUS Act.
Compliance Concerns Drive OCC Decision
In its formal decision, the OCC concluded that Wise had failed to demonstrate sufficiently robust Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) controls to justify the granting of a national trust bank charter.
The regulator highlighted several concerns, including deficiencies in Wise’s existing AML/CFT programme, weaknesses in its proposed compliance framework, and a lack of evidence that the organisation could meet the enhanced regulatory obligations imposed on federally chartered banking institutions.
The OCC also questioned whether the proposed board and senior management team possessed sufficient experience overseeing AML compliance and fiduciary banking activities. Taken together, the regulator said the application presented “significant supervisory and compliance concerns”.
The decision follows a multistate enforcement action in July 2025, when six U.S. state regulators reached a $4.2 million settlement with Wise over deficiencies in its anti-money laundering programme.
Wise Looks to a Changing Regulatory Environment
Despite the rejection, the OCC made clear that Wise is free to submit a new application, an invitation the company has already accepted.
Wise says the application under review reflected its business as it existed more than a year ago and does not account for substantial investments made since then in compliance, customer due diligence, transaction monitoring and financial crime controls.
The company has also pointed to significant regulatory developments since its original submission. Chief among these are the passage of the GENIUS Act, which establishes a federal framework for payment stablecoins, and evolving Federal Reserve policy governing access to the U.S. payments system.
Wise believes these changes create a more suitable environment for a revised charter application focused on interoperability between traditional payment rails and emerging digital asset infrastructure.
Strategic Importance Beyond Banking
Obtaining a national trust bank charter would represent far more than a regulatory milestone. It would provide Wise with greater control over payment infrastructure, treasury management and settlement capabilities while potentially reducing reliance on correspondent banking partners.
The company currently operates under money transmitter licences across 48 U.S. states and four territories, alongside more than 80 regulatory licences globally, allowing its existing services to continue uninterrupted.
Wise argues that its technology platform is increasingly well positioned to connect conventional banking systems with new forms of digital money, particularly as stablecoins begin to integrate with mainstream payment networks.
The episode also illustrates the increasingly high regulatory expectations facing fintech firms seeking banking licences. Innovation alone is no longer sufficient; regulators are demanding that digital-first payment companies demonstrate governance, operational resilience and financial crime controls comparable with those expected of established banking institutions.
For Wise, the next application will therefore serve as a test not only of its compliance improvements, but also of whether fintechs can successfully transition from licensed payment providers to fully regulated banking organisations within the rapidly evolving U.S. financial ecosystem.
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