Wise US
The OCC denied Wise's application to establish Wise National Trust, a proposed US national trust bank charter. Wise filed the application in Jun 2025, planning to offer stored-value accounts, debit cards, fiduciary services, and payment processing to US customers and third parties. One month after filing, Wise's US subsidiary became subject to a public Multistate Consent Order over alleged BSA/AML/CFT programme deficiencies.
The order cited failures in investigating and reporting suspicious activity, transaction-monitoring data integrity concerns, and untimely filing of suspicious activity reports. 2 million administrative fine. The OCC concluded it could not determine that the proposed trust bank would maintain an effective AML/CFT compliance programme.
Wise said it plans to submit a new application under the GENIUS Act framework.
- Demonstrates that prior AML/BSA enforcement actions can be disqualifying for fintechs seeking bank charters
- Raises the bar for fintech companies applying for national trust bank charters, requiring demonstrated compliance track records
- Signals OCC willingness to deny charter applications based on compliance concerns, affecting BaaS and embedded finance firms with banking ambitions
- Highlights that multistate consent orders can have cascading effects on federal charter applications
- NewsFintech Futures