OCC Denies Wise Trust Bank Charter Over AML Deficiencies
The Office of the Comptroller of the Currency denied Wise’s national trust bank application after citing AML and governance concerns, leaving the fintech to rebuild its U.S. charter plan under a GENIUS Act framework.
A U.S. trust-bank charter path for Wise has narrowed around compliance rather than product demand, after the Office of the Comptroller of the Currency denied the London-based fintech’s application.
Banking Dive reported that the OCC letter named anti-money-laundering concerns, past state actions and proposed leadership experience as reasons the regulator would not approve the national trust bank.
The decision moves the company’s U.S. payment-rail plan into a remediation phase.
A national trust bank could have moved the fintech closer to federal banking infrastructure; the OCC decision instead ties any next application to stronger Bank Secrecy Act, AML and counter-terrorist financing controls.
OCC Letter Centres On AML Controls
The Tuesday OCC letter from Stephen Lybarger, senior deputy comptroller for chartering, organisation and structure, calls the application a source of “significant supervisory and compliance concerns.” The document points to state regulatory actions tied to AML compliance and questions organisers’ familiarity with federal banking laws and regulations.
The multi-state consent order in July 2025 required the company’s U.S. arm to increase compliance investment after deficiencies in Bank Secrecy Act, AML and counter-terrorist-financing programmes.
California regulators issued a separate consent order covering state-specific requirements.
For the proposed trust bank, the control gap reached governance and fiduciary operations.
The OCC determined that AML/CFT compliance would remain lacking until existing deficiencies were addressed through an enhanced enterprise-wide programme.
The letter also treated the money-services-business record as insufficient evidence that the proposed bank could meet the additional AML/CFT duties applied to national trust banks.
GENIUS Act Framework Shapes The Resubmission Plan
The Thursday filing presents business and compliance maturity as changed since the original application.
It also keeps a replacement filing under a GENIUS Act framework as the intended route back to the OCC.
That resubmission plan moves the matter beyond a single application rejection into the policy path for payment firms and stablecoin-adjacent banking access.
Access to U.S. domestic rails depends on the regulator accepting the company’s control environment, proposed governance and remediation record, not only on customer demand for cross-border payment services.
The OCC handbook gives the agency a 120 days target for application decisions, while the current record shows how supervisory findings can overtake that timetable.
Lybarger’s letter places proposed organisers within long-standing AML/CFT deficiencies at the U.S. business and faults the proposed directors and managers for experience gaps in fiduciary activities, legal requirements and financial-crime controls.
Charter Denial Sets The Compliance Proof Point
The decision lands during a broader wave of charter applications under the second Trump administration.
The regulatory record still requires control evidence, experienced bank leadership and credible remediation of past consent-order findings before a fintech charter can clear the OCC.
The replacement application remains unfiled in the disclosed record, leaving any new OCC review dependent on the remediation record and the regulator’s treatment of payment-account access under the GENIUS Act framework.
