Dive Brief:

• The Office of the Comptroller of the Currency has denied London-based Wise’s application to establish a national trust bank.
• In a Tuesday letter, Stephen Lybarger, the OCC’s senior deputy comptroller for chartering, organization and structure, said Wise’s application “presents significant supervisory and compliance concerns.” He pointed to state regulatory actions taken against Wise related to anti-money laundering compliance and that organizers didn’t demonstrate “sufficient familiarity” with federal banking laws and regulations.
• Wise plans to submit a new application to the OCC for a national trust bank charter under a Genius Act framework, the company said in a Thursday filing.

Dive Insight:

In July 2025, less than a month after submitting its application to the OCC, the company’s U.S. arm was hit with a multi-state consent order over deficiencies in its Bank Secrecy Act, anti-money laundering and countering the financing of terrorism programs. 

Wise US agreed to pay $4.2 million and boost its compliance investments as part of the order that revealed flaws in how the company addressed certain compliance requirements. California regulators also issued their own consent order with Wise US to address certain requirements specific to that state. 

Lybarger noted “significant enforcement actions such as these are important to, but do not ultimately control,” the OCC’s application decisions. The denial appears to be the first from the OCC amid the current influx of charter applications during the second Trump administration. 

The OCC determined the proposed trust bank’s AML/CFT compliance would be lacking, “until Wise has addressed existing deficiencies and develops an enhanced enterprise-wide AML/CFT program.” 

Wise US has a record of compliance failure with money services businesses requirements, and the company’s application “does not support a conclusion” that it will be able to meet added AML/CFT requirements trust banks are subject to, Lybarger wrote.

Since submitting its application more than a year ago, “our business and compliance maturity have evolved significantly,” the British fintech said in its Thursday filing. 

“This includes changes we have made in response to OCC feedback throughout the application process, and the OCC’s letter published today refers to these historical issues with our original application that we have been addressing. We look forward to submitting a viable application to the OCC in due course which reflects both our growing business and the changing regulatory landscape.”

The OCC aims to make decisions on applications within 120 days, according to its handbook. 

Lybarger also had harsh words regarding proposed leadership of the would-be trust bank. “Organizers are part of long-standing AML/CFT deficiencies at Wise US,” which “has been in continuing noncompliance” with federal AML/CFT requirements, the letter said.

That the organizers “failed to select appropriate directors and management officials with sufficient experience” with AML/CFT requirements and operations or with fiduciary activities “did not reflect favorably on the application,” Lybarger wrote.  

The proposed management and board failed to demonstrate “sufficient competence” related to services the trust bank would provide, “most notably with respect to legal and regulatory requirements relating to the exercise of fiduciary activities by national banks as well as AML/CFT requirements,” the letter said. 

Proposed leaders “have demonstrated a persistent inability to sufficiently manage” money-laundering and illicit finance risks associated with the proposed trust bank’s activities, and organizers “collectively failed to demonstrate sufficient experience with relevant banking laws and regulations related to fiduciary activities,” Lybarger wrote. 

“Further, Wise US has no historical experience with fiduciary activities, and proposed management and directors failed to demonstrate sufficient experience with the fiduciary activities of national banks, including the OCC’s regulations governing such activities,” the letter said.

The denial doesn’t preclude Wise from filing another trust bank application, but the agency expects any subsequent application would “satisfactorily address the reasons for this action,” Lybarger wrote.

In addition to the substance of the issue, “the OCC also has to think about the consequences of not issuing a denial to an entity that receives a large, public, multi-state consent order,” said Carl Goss, a Dallas-based partner at law firm Hunton Andrews Kurth. 

Given the consent order, “it seems like, at that point, a denial would have been pretty much a foregone conclusion,” said Goss, a former OCC lawyer. “I have to think [Wise] understood that that was going to be an issue.”

“Everyone is always sensitive to AML considerations,” Goss said. “It's difficult to act favorably on an application if there are even large alleged issues with AML.”

On Thursday, Wise said it has strengthened its U.S. program, enhanced investigation and reporting processes, improved data integrity and increased compliance resourcing.

William Blair analyst Cristopher Kennedy, in a Friday note, said about one-third of Wise’s workforce is focused on financial crime prevention.

“We have invested significantly in enhancing our processes and controls globally and in the U.S. since the original application for the trust charter was prepared, including those to prevent financial crime alongside other forms of risk,” Wise said in its filing. “Preventing bad actors from using financial institutions like Wise is of the utmost importance to us.”

Since the company has immediately said it plans to submit a new application, Wise may have gotten some indication from the OCC that a future application could be more favorably received, “or this thing is such a big part of [Wise’s] business plan, that they're comfortable burning the resources even without such statements,” Goss said.

In light of the OCC’s critiques of proposed management, Wise may try to retrain those leaders so that they can demonstrate sufficient competence under a new application process, Goss said.  

But “if I were them, I would just find new management when I repropose,” he said. “It's also a message to future applicants that people are important, and that’s something to think hard about when you’re submitting these applications.”

A spokesperson for Wise declined to comment Friday on proposed management under another trust bank application, or how soon it might reapply. 

Mike Boush, named in the application as the proposed CEO of Wise National Trust, appears to have left the company in December 2025, according to his LinkedIn page. The OCC’s letter was addressed to Satyan Melwani, Wise’s head of North America banking and expansion since January, according to his LinkedIn profile. 

In its Thursday statement, Wise also noted its application approach became “non-viable” following a Federal Reserve master account change proposed in May, since Wise’s application depended on receiving direct master account access at the central bank.

But the company indicated it sees new opportunities under the Genius Act.

“With digital assets, such as stablecoins, becoming more visible alongside existing payment rails, Wise's infrastructure is well positioned to play an important interoperability role in this changing ecosystem,” the fintech said. “Our ability to efficiently connect payment systems, operate treasury management, and control risk in a regulated environment are more relevant than ever before to deliver even greater outcomes for customers.”