Banking and Finance Law Daily Wrap Up, BANKING OPERATIONS—OCC denies Wise National Trust charter application, (Jul 24, 2026)

By Patricia K. Ruiz, J.D.

Following the denial, Wise says it plans to submit a new application under a GENIUS Act framework.

The Office of the Comptroller of the Currency (OCC) has denied an application by Wise US Holdings Inc. to establish Wise National Trust, a proposed national trust bank in Austin, Texas. The OCC found that the application did not demonstrate that the proposed institution would operate in compliance with applicable laws and regulations and concluded that the organizers, management, and board lacked sufficient experience in key banking and fiduciary functions. Following the decision, Wise said the denial relates to issues in its original application, emphasized that its existing operations are unaffected, and announced plans to submit a new national trust bank charter application.

Application. The application sought a charter for Wise National Trust, which would have operated as a subsidiary national trust bank sponsored by Wise US Holdings, an indirect subsidiary of Wise plc. According to the OCC, the proposed institution planned to offer multi-currency accounts with debit cards directly to U.S. customers, provide payment-processing services to customers, affiliates, and third parties, and perform fiduciary services for multi-currency account customers and Wise US.

The OCC said Wise US currently operates as a licensed money transmitter in 48 states and that activities conducted by Wise US generally would have been transferred to the proposed trust bank. The agency stated that the charter proposal was intended to create efficiencies in Wise’s U.S. payments operations and support future growth.

AML/CFT compliance concerns. A significant factor in the OCC’s decision was a July 9, 2025, multistate consent order involving Wise US. The agency noted that the order addressed deficiencies in Wise US’s Bank Secrecy Act, anti-money laundering, and countering the financing of terrorism program and identified violations of state and federal law. According to the OCC, the order cited deficiencies involving suspicious activity investigations and reporting, transaction-monitoring data integrity, untimely suspicious activity reports, independent review requirements, and the failure to timely correct previously identified deficiencies. Wise US agreed to pay a $4.2 million administrative penalty, while the California Department of Financial Protection and Innovation issued a separate consent order addressing California-specific matters. The OCC emphasized that, while enforcement actions do not control charter decisions, they are important considerations in evaluating applications.

Analysis of proposed compliance framework. The OCC concluded that the application failed to demonstrate that Wise National Trust would operate in compliance with applicable laws and regulations. The agency said the proposed trust bank would significantly rely on Wise US and other Wise affiliates for AML/CFT compliance functions. Given Wise’s global payments business and the volume of activity conducted across the enterprise, the OCC stated that it would expect an AML/CFT program commensurate with those risks.

Based on the consent orders, information from regulators, its review of the proposed compliance program, and other information in the record, the OCC said it could not conclude that the proposed institution would have an effective AML/CFT compliance program. The agency stated that Wise must address existing deficiencies and develop an enhanced enterprise-wide AML/CFT program before such concerns could be resolved.

The OCC found that the application did not adequately address key deficiencies in the proposed AML/CFT risk-management framework. In addition, the agency noted that national banks are subject to AML/CFT requirements beyond those applicable to money services businesses and stated that the application did not support a conclusion that the proposed institution would be able to comply with those additional requirements.

Management and organizer qualifications. The OCC found that the organizers did not demonstrate sufficient familiarity with national banking laws and regulations. The agency cited what it described as long-standing AML/CFT deficiencies at Wise US and stated that the organizers failed to select directors and management officials with sufficient experience in AML/CFT requirements and operations.

The OCC further concluded that the proposed management team and board did not demonstrate sufficient competence relevant to the services the institution planned to provide, particularly with respect to fiduciary activities and AML/CFT obligations. According to the decision, the proposed activities presented high inherent risks relating to money laundering, terrorist financing, and other illicit finance activity. The agency stated that the proposed management and board collectively had demonstrated a persistent inability to sufficiently manage those risks.

Fiduciary experience deficiencies. The OCC separately determined that the organizers failed to demonstrate sufficient experience with banking laws and regulations governing fiduciary activities. The agency noted that Wise US has no historical experience conducting fiduciary activities. It also found that the proposed directors and management failed to demonstrate sufficient experience with fiduciary activities conducted by national banks, including the OCC’s regulations governing those activities under 12 C.F.R. Part 9. The OCC stated that the failure to select directors and management officials with sufficient fiduciary expertise weighed against approval of the application.

Decision. The OCC denied the application under 12 C.F.R. § 5.13(b), concluding that it presented significant supervisory and compliance concerns and that approval would be inconsistent with the policies set forth in the agency’s chartering regulations.

Because the charter application was denied, the OCC stated that related requests for fiduciary powers and waivers of director residency and citizenship requirements were moot and would not be acted upon. The agency added that the denial does not prohibit the filing of a future de novo charter application and advised that the decision may be appealed to the OCC Ombudsman.

Wise response, plans for new application. In a statement filed with the Securities and Exchange Commission, Wise said the OCC’s decision denied its application for a national trust bank charter “at this time” and that the company’s business and compliance maturity had evolved significantly since the application was submitted more than a year earlier. Wise said it had made changes in response to OCC feedback during the application process and described the issues identified by the agency as historical issues associated with the original application.

The company said the OCC’s decision does not affect its existing operations under its money transmitter licenses in 48 states and four territories or its portfolio of more than 80 licenses globally. Wise stated that, following the July 2025 consent order, it strengthened its U.S. compliance program, enhanced investigation and reporting processes, improved data integrity controls, and increased compliance staffing.

Wise also said that the regulatory environment had changed since the original application was submitted. The company pointed to a May 2026 Federal Reserve proposal concerning payment-system access and said its original application had been conditioned on obtaining direct access to Federal Reserve master accounts. According to Wise, the Federal Reserve’s pause on account access for uninsured trust banks rendered the approach in the original application nonviable. Wise also cited enactment of the GENIUS Act and evolving Federal Reserve policies regarding access to the federal payments network.

The company said it has informed the OCC that it plans to submit a new application for a national trust bank charter under a GENIUS Act framework.

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