The OCC said in a corporate decision dated Tuesday (July 21) that it denied the application from Wise US Holdings, Wise’s indirect subsidiary, because Wise has not yet addressed deficiencies in its Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) program, did not address in the application deficiencies in its proposed AML/CFT risk management program, and did not demonstrate in the application that it would be able to comply with the additional AML/CFT requirements applicable to banks.
The regulator noted that in July 2025, Wise US became subject to a multistate consent order relating to deficiencies in its AML/CFT program. The OCC said these orders, together with information from other regulators and the OCC’s own review of the company’s proposed compliance program, contributed to its decision.
PYMNTS reported in July 2025 that six state regulators secured a $4.2 million multistate settlement from Wise US that resolved the regulators’ allegations that the company had inadequacies in its AML/CFT program.
The OCC also said in its letter that it determined that the organizers of the proposed national trust bank failed to select directors and management officials with sufficient experience with AML/CFT requirements, that the proposed national trust bank’s activities would present high AML/CFT risks, and that the organizers failed to demonstrate sufficient experience with banking laws and regulations related to fiduciary activities.
The regulator concluded that it denied the application because it “presents significant supervisory and compliance concerns.” The OCC added that the denial “does not prohibit the filing of a de novo charter application in the future.”
In a Friday press release in which Wise said it will submit a new application, the company said since submitting the original application over a year ago, it has made changes in response to feedback it received from OCC during the application process as well as the demands of the July 2025 multistate consent order.
Wise also pointed to regulatory changes that have taken place in the U.S. since it submitted its original application. These include the enactment of the GENIUS Act and the rapidly evolving Federal Reserve policy on how financial institutions can directly access the federal payment network, the company said.
“With digital assets, such as stablecoins, becoming more visible alongside existing payment rails, Wise’s infrastructure is well positioned to play an important interoperability role in this changing ecosystem,” the company said in the release. “Our ability to efficiently connect payment systems, operate treasury management, and control risk in a regulated environment are more relevant than ever before to deliver even greater outcomes for customers.”
“Based on the above, we have informed the OCC that we plan to submit a new application for a national trust bank charter under a GENIUS Act framework, as we continue to maintain a positive relationship with the agency,” Wise said.
Facts Only
* The OCC denied the application from Wise US Holdings on July 21.
* Denial reasons included failure to address AML/CFT program deficiencies, lack of addressing application deficiencies in the proposed AML/CFT risk management program, and failure to demonstrate compliance with additional AML/CFT requirements for banks.
* Wise US became subject to a multistate consent order regarding AML/CFT program deficiencies in July 2025.
* Six state regulators secured a $4.2 million multistate settlement from Wise US concerning AML/CFT program inadequacies in July 2025.
* The OCC determined that organizers of the proposed national trust bank failed to select directors and management officials with sufficient AML/CFT experience.
* The OCC found the proposed national trust bank’s activities presented high AML/CFT risks.
* The organizers failed to demonstrate sufficient experience with banking laws related to fiduciary activities.
* Wise informed the OCC it plans to submit a new application for a national trust bank charter under a GENIUS Act framework.
* Wise stated it made changes in response to OCC feedback and the July 2025 multistate consent order since submitting its original application over a year ago.
Executive Summary
Full Take
The narrative reveals a tension between a company’s operational ambition—leveraging digital infrastructure for interoperability in a new regulatory environment—and the strict demands of existing compliance frameworks. The pattern emerging is that regulatory scrutiny, initiated by prior consent orders and subsequent settlements, acts as an antecedent condition that shapes current application outcomes. The denial was not solely about Wise's internal program but incorporated external findings regarding governance (director/management experience) and inherent risk (banking activities). This suggests that regulatory authority operates by layering deficiencies: past infractions build a context of heightened suspicion, which is then judged against the specific requirements of a new institutional application. The response, opting for a new charter under the GENIUS Act framework, frames future compliance as a matter of proactive evolution rather than retroactive remediation. The underlying implication is that achieving regulatory approval requires not just demonstrating current compliance but successfully integrating historical accountability into prospective organizational structure and governance to satisfy external oversight bodies.
Bridge Questions: How do multistate settlement outcomes influence the standard for future application review? What specific mechanisms could streamline the integration of prior consent order findings into new charter applications? Does the reliance on evolving legislation like the GENIUS Act create an implicit expectation that systemic risk remediation will be addressed through legislative change rather than solely through direct operational demonstration?