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Regulation

OCC denies Wise’s national trust bank charter over AML gaps

The OCC rejected Wise’s bid for a national trust bank charter on July 21, citing AML/CFT failings the group had not fixed. Wise disclosed the decision on July 24, its shares fell as much as 11%, and it plans to reapply under a GENIUS Act framework.

The Office of the Comptroller of the Currency (OCC) has denied Wise’s application to charter a national trust bank, finding that it “presents significant supervisory and compliance concerns.” The decision, dated July 21, 2026, and published as Corporate Decision #1381, halts, for now, the London-based payments group’s plan to open a bank subsidiary, Wise National Trust, in Austin, Texas. Wise disclosed the denial on July 24, and its shares fell as much as 11% during the session.

The regulator’s reasoning turns on anti-money laundering compliance, and it reaches beyond the proposed bank to the group behind it. Wise says it will file again, this time under the GENIUS Act, the federal law on payment stablecoins. For other payment companies and stablecoin issuers seeking federal charters, the decision sets out how the OCC weighs an applicant’s compliance history.

July 21, 2026
Date of the OCC denial
OCC, Corporate Decision #1381
$240B+
Cross-border volume Wise processed in fiscal 2026
Wise, announcement of July 24, 2026
19 million
Personal and business customers served in fiscal 2026
Wise
$4.2M
Administrative penalty under the July 2025 multistate consent order
OCC

A charter to cut reliance on correspondent banks

A national trust bank holds a federal charter to provide fiduciary and custody services. Unlike a conventional deposit-taking bank, it is built around that fiduciary business, and its deposits are not insured by the FDIC. The application was sponsored by Wise US Holdings, the group’s US holding company, and covered three lines of business:

  • Stored value accounts with debit cards, the multi-currency accounts Wise offers to US customers.
  • Payment processing for its direct customers, its domestic and foreign affiliates, and third parties, including other financial institutions.
  • Fiduciary services for holders of those multi-currency accounts and for Wise US.

The decision spells out the business case. Wise US Holdings currently operates in the US through numerous correspondent banking relationships, the OCC notes. A bank of its own, with a potential Federal Reserve master account, “is expected to benefit Wise’s future growth and enable its U.S. operations to scale efficiently.”

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Why a master account carries so much weight
Without a master account at a central bank, a payment provider relies on a partner bank to hold customer funds and to reach settlement infrastructure. That dependence has costs: shared margin, delays, and concentration risk on a single partner. It is what makes a federal charter attractive to money transfer companies and stablecoin issuers alike.
Documents and a pen on a desk, illustrating a regulatory decision
The OCC’s decision is public and lays out the chartering criteria an applicant must meet.

OCC points to AML/CFT failings across the group

The OCC relied on 12 CFR 5.13(b), which allows it to deny an application “if a significant supervisory or compliance concern exists,” and on the chartering criteria in 12 CFR 5.20(f): organizers familiar with national banking law, competent management and board, sufficient capital, a reasonable prospect of profitability, and safe and sound operation. It found the application fell short on several counts.

  • The application did not show that the bank would comply with AML/CFT laws. It would have relied heavily on the programs of Wise US and other group entities, whose deficiencies had not been fixed.
  • The organizers did not adequately address key deficiencies in the AML/CFT risk management program they proposed.
  • A bank faces heavier AML/CFT requirements than a money services business, and the OCC found that Wise US has a record of failing to comply with the rules that already apply to MSBs.
  • The proposed management and board did not show sufficient experience with the fiduciary activities of national banks, which are governed by 12 CFR 9.
June 2025
Application filed
The group’s US holding company sponsors the creation of Wise National Trust in Austin, Texas.
July 9, 2025
Multistate consent order
Less than a month after the filing, Wise US becomes subject to a public order over its BSA/AML program: late suspicious activity reports, transaction monitoring data integrity, independent reviews not done often enough, and prior audit findings not corrected in time. It agrees to a $4.2 million administrative penalty divided among the participating regulators, and California’s financial regulator issues a separate order.
May 2026
The Fed changes course
According to Wise, the Federal Reserve’s proposed change to payment system access, which generally pauses master accounts for uninsured trust banks, made the original structure of its application unworkable.
July 21, 2026
OCC denies the application
The decision is signed by Stephen A. Lybarger, Senior Deputy Comptroller for Chartering, Organization and Structure.
July 24, 2026
Disclosure and market reaction
Wise announces the decision and a new application. The shares fall as much as 11% during the day.
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The consent order alone did not sink the bid
The OCC writes that “significant enforcement actions such as these are important to, but do not ultimately control, the OCC’s decisions with respect to charter applications.” The application failed because Wise did not show that the deficiencies had been fixed across the group, rather than because of the 2025 consent order itself.

Wise plans a second bid under the GENIUS Act

Wise is not walking away. “We plan to submit a new application for a national trust bank charter under a GENIUS Act framework,” the company said, adding that it has informed the OCC. Since the original filing, it says, “we have strengthened our local U.S. program, enhanced our investigation and reporting processes, improved the integrity of the data we collect from our customers and increased resourcing for our local compliance program.”

The OCC left that door open. “The denial of the Application does not prohibit the filing of a de novo charter application in the future,” it wrote, citing OCC Bulletin 2026-27 on its filing decision process, dated June 17, 2026. Wise can also appeal to the agency’s ombudsman under 12 CFR 5.13(f). Any later application, the OCC added, will be expected to satisfactorily address the reasons for this denial.

Server room, illustrating compliance and transaction monitoring infrastructure
Transaction monitoring, suspicious activity reporting, data quality: AML/CFT compliance comes down to tooling and staffing.

The OCC judges the parent, not just the bank

Wise’s US business is unaffected. It continues to operate under money transmitter licenses in 48 states and four territories, alongside more than 80 licenses worldwide. The signal to the market is elsewhere. For a fintech, a trust bank charter still depends on the applicant’s compliance record, and when the bank would lean on its parent’s controls, the OCC assesses the maturity of the whole group, not just the proposed subsidiary.

That lesson applies to similar applications from cross-border payment companies and stablecoin issuers. Three things to watch: the timing of Wise’s new filing, the outcome of any appeal to the ombudsman, and how the OCC handles the next applications built on the stablecoin framework.

Provenance

Published July 25, 2026

4 sources, 4 distinct domains

↗ OCC · Corporate Decision #1381, July 21, 2026 (PDF) · occ.gov↗ Wise · Wise US National Trust Bank Charter Application, RNS, July 24, 2026 (Investegate) · investegate.co.uk↗ Forbes · Wise suffers setback in US expansion as regulator denies bank license · forbes.com↗ PYMNTS · Wise prepares second US bank charter bid after OCC rejection · pymnts.com
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