OCC Rejects Wise's U.S. Trust Bank Charter Application Over AML Compliance Concerns

The U.S. Office of the Comptroller of the Currency (OCC) has rejected Wise's application to establish a national trust bank, citing significant deficiencies in the company's anti-money laundering and counter-terrorist financing (AML/CFT) framework, as well as concerns over governance, regulatory expertise and overall readiness to operate as a federally chartered banking institution. The decision represents a major regulatory setback for the global payments company as it seeks to expand its presence in the United States.

In its decision, the OCC concluded that Wise had not adequately addressed existing weaknesses in its AML/CFT programme and had failed to demonstrate that the proposed trust bank would be capable of meeting the more stringent compliance obligations applicable to federally regulated banking institutions. Regulators also determined that the application did not provide sufficient evidence that the company could effectively manage the heightened financial crime risks associated with operating a national trust bank.

The regulator's concerns were influenced by a multistate consent order issued in 2025 against Wise's U.S. business, which identified shortcomings in its Bank Secrecy Act and AML/CFT compliance programme. The enforcement action highlighted deficiencies in transaction monitoring, suspicious activity reporting, data integrity, independent compliance reviews and the timely remediation of previously identified issues. As part of the settlement, Wise agreed to pay US$4.2 million and implement significant enhancements to its financial crime controls.

Beyond compliance shortcomings, the OCC also questioned the experience and suitability of the proposed leadership team. According to the regulator, the organisers did not demonstrate sufficient expertise in national banking laws, fiduciary activities or the specialised AML/CFT requirements applicable to trust banks. The OCC concluded that the proposed management and board lacked the experience necessary to oversee a federally chartered institution operating in a high-risk financial environment.

Despite rejecting the application, the OCC made clear that the decision does not prevent Wise from submitting a new application in the future. The regulator indicated that any future proposal would need to comprehensively address the supervisory and compliance concerns identified during the review process, including the strengthening of enterprise-wide AML controls and improvements in governance and management expertise.

Wise has stated that its compliance capabilities have evolved significantly since the original application was submitted and that it has invested heavily in strengthening its financial crime controls in response to regulatory feedback. The company also noted that changes to the U.S. regulatory landscape, including the introduction of the GENIUS Act framework, have altered the environment in which its original application was prepared. It has confirmed its intention to submit a revised application that reflects both its enhanced compliance programme and the updated regulatory framework.

The OCC's decision sends a strong message to fintech firms seeking banking licences in the United States that robust AML/CFT programmes, experienced governance structures and demonstrable regulatory expertise remain essential prerequisites for obtaining federal approval. As more financial technology companies pursue banking charters to expand their services, regulators appear determined to maintain rigorous supervisory standards and ensure that applicants can effectively manage the financial crime risks associated with operating within the U.S. banking system.

By fLEXI tEAM