Strategic Insights into Banking & Fintech

OCC rejects Wise’s national trust bank charter application

U.K. fintech Wise is headed back to the drawing board in its effort to form a U.S. national trust bank.

The Office of the Comptroller of the Currency denied the company’s application.

Stephen Lybarger, the OCC’s senior deputy comptroller for chartering, organization and structure, said in a letter that the application “presents significant supervisory and compliance concerns.” He noted state regulatory actions taken against Wise tied to anti-money laundering compliance, adding that organizers failed to demonstrate “sufficient familiarity” with federal banking laws and regulations.

Wise said in a filing that it plans to submit a new application to the OCC under a Genius Act framework.

In July 2025, Wise’s U.S. arm was hit with a multi-state consent order over deficiencies in its Bank Secrecy Act, AML, and countering the financing of terrorism (CFT) programs.  The U.S. operations agreed to pay $4.2 million and boost its compliance investments as part of the order.

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.”

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