OCC Rejects Wise U.S. Trust Bank Charter Application

OCC REJECTS WISE’S U.S. TRUST BANK CHARTER APPLICATION

The Office of the Comptroller of the Currency, or OCC, has denied Wise’s application to establish a subsidiary national trust bank in the United States.

The proposed institution would have been named Wise National Trust and based in Austin, Texas. The OCC issued its formal decision on 21 July 2026, while Wise publicly announced the rejection on 24 July.

According to the regulator, the application presented significant supervisory and compliance concerns and did not satisfy the policies used to assess applications for new national banks.

The rejection is not a permanent prohibition on Wise obtaining a U.S. national trust bank charter. The OCC stated that the decision does not prevent Wise from submitting another application in the future.

Wise has confirmed that it intends to apply again under a different regulatory structure.

WHAT WISE NATIONAL TRUST PLANNED TO OFFER

Wise National Trust was intended to provide multi-currency stored-value accounts with debit cards directly to customers in the United States.

The proposed bank would also have processed payments for Wise customers, Wise affiliates and third parties, including other financial institutions. Its planned activities included fiduciary services for multi-currency account customers and Wise’s U.S. business.

Wise currently conducts its U.S. operations through money-transmitter licences and correspondent banking relationships.

Creating a national trust bank, combined with potential access to a Federal Reserve master account, was intended to improve the efficiency and scalability of Wise’s U.S. payment infrastructure.

However, obtaining a national trust bank charter would not automatically have guaranteed access to every Federal Reserve payment service. Access to a master account would still have depended on separate Federal Reserve policies, eligibility requirements and decisions.

WHY THE OCC DENIED THE APPLICATION

A central issue in the OCC’s decision was Wise US’s previous compliance record.

In July 2025, Wise US became subject to a public multistate consent order involving deficiencies in its Bank Secrecy Act, anti-money-laundering and counter-terrorist-financing programme.

The consent order identified issues involving suspicious-activity investigations, transaction-monitoring data integrity and delays in filing suspicious activity reports.

It also referred to the frequency of independent compliance reviews and the timely correction of deficiencies previously identified through regulatory examinations and internal audits.

Wise US agreed to pay a $4.2 million administrative penalty, divided among the participating state regulators.

The OCC said an earlier enforcement action does not automatically determine whether a charter application will be approved or rejected. However, it concluded that Wise’s application had not demonstrated that the proposed trust bank would operate in compliance with applicable laws and regulations.

The regulator said it could not conclude that Wise National Trust would have an effective AML/CFT compliance programme until Wise addressed existing deficiencies and developed enhanced enterprise-wide controls appropriate for the company’s scale and risk profile.

OCC ALSO QUESTIONED MANAGEMENT EXPERIENCE

The OCC examined whether the proposed organisers, directors and executives had sufficient knowledge and experience to operate a national trust bank.

It concluded that the organisers had not demonstrated sufficient familiarity with U.S. national banking laws and regulations.

The regulator also said the proposed management team and board had not demonstrated adequate competence in the requirements governing fiduciary activities and bank-level AML/CFT obligations.

This distinction matters because Wise US currently operates as a money-services business. A national trust bank would be subject to additional federal banking requirements and supervisory expectations.

The OCC stated that Wise US had no historical experience with fiduciary activities. It also concluded that the proposed directors and executives had not demonstrated sufficient experience with the fiduciary responsibilities of national banks.

The regulator therefore evaluated both Wise’s existing compliance record and the proposed bank’s ability to manage the additional obligations created by a national charter.

WISE SAYS ITS CURRENT OPERATIONS ARE UNAFFECTED

Wise said the OCC’s decision does not affect its normal operations in the United States or other markets.

The company continues to operate through money-transmitter licences across 48 U.S. states and four territories, alongside what it describes as a portfolio of more than 80 licences globally.

Wise said it has strengthened its U.S. compliance programme since the original national trust bank application was prepared.

The company reported that it had enhanced investigation and reporting processes, improved the integrity of customer data and increased resources for its local compliance programme.

Wise also said it had invested in controls intended to prevent financial crime across its U.S. and global operations.

These statements describe improvements reported by Wise. They do not replace or alter the findings contained in the OCC’s formal charter decision.

FEDERAL RESERVE PAYMENT-ACCESS POLICY ALSO CHANGED

Wise said its original application was based partly on the expectation that the proposed trust bank could obtain direct access to a Federal Reserve master account.

Since the application was submitted, the Federal Reserve has proposed a new category of special-purpose Payment Accounts and encouraged Reserve Banks to pause decisions on certain account requests from Tier 3 institutions while the policy is developed.

Wise said the Federal Reserve’s approach to account access for uninsured trust banks made the structure used in its original application no longer viable.

The company also pointed to the enactment of the GENIUS Act and the changing regulatory treatment of stablecoins and digital payment infrastructure.

Wise now plans to submit another national trust bank application under what it calls a GENIUS Act framework.

The company has not disclosed when the new application will be filed, how the proposed institution will be structured or which digital-asset activities may be included.

WHAT THE DECISION MEANS FOR PAYMENT COMPANIES

The OCC’s decision demonstrates that obtaining a U.S. banking charter requires more than presenting a technology platform, customer-growth strategy or plan for direct payment-system access.

Regulators assess an applicant’s existing compliance record, management experience, corporate governance, financial-crime controls and ability to meet bank-level obligations.

A payment company seeking direct access to national payment infrastructure may therefore need to demonstrate that its controls are suitable for both its current business and the additional risks created by the proposed bank.

The decision also shows that an applicant’s wider group-level compliance record can affect the assessment of a new regulated subsidiary.

For cross-border payment companies, a banking charter may reduce reliance on intermediaries and support more direct settlement. However, it also introduces more extensive regulatory, fiduciary, governance and AML/CFT responsibilities.

WHAT TO WATCH NEXT

The OCC’s rejection does not permanently prevent Wise from becoming a national trust bank.

Any future application will need to address the compliance, management and supervisory deficiencies identified in the July 2026 decision.

The next developments to monitor include whether Wise submits a new application, how it structures the proposed institution under the GENIUS Act and how Federal Reserve policy evolves for special-purpose payment accounts.

Wise’s existing services remain operational, but its plan to establish a federally chartered trust bank in the United States will require a new application and another regulatory review.