The Office of the Comptroller of the Currency has denied Wise’s application to establish a U.S. national trust bank, delivering a regulatory setback to the cross-border payments company as it seeks to expand its infrastructure and reduce dependence on intermediary financial institutions in one of its largest potential markets.

The decision covers Wise National Trust, a proposed nondepository national trust bank that would have been based in Austin, Texas. The OCC’s formal ruling was dated July 21 and disclosed by Wise on July 24. The company said the regulator had informed it that the application was being denied “at this time,” while emphasizing that the outcome does not interrupt Wise’s existing consumer, business or institutional payment services.

The proposed institution was designed to offer stored-value multicurrency accounts with debit cards directly to U.S. customers, provide payment processing to Wise customers, affiliates and third-party financial institutions, and conduct fiduciary activities for account holders and Wise US. Those functions would have moved important elements of the company’s U.S. operations into a federally supervised trust-bank structure.

Wise currently conducts its American business through Wise US and a network of state money-transmitter licenses. The company said it remains licensed in 48 states and four U.S. territories and holds more than 80 regulatory licenses globally. Customers can therefore continue using Wise’s existing products despite the charter decision.

The OCC’s denial focused principally on financial-crime compliance, management capability and the organizers’ familiarity with federal banking requirements. In its five-page decision, the regulator said it could not conclude that the proposed trust bank would have an effective anti-money-laundering and counter-terrorist-financing program until existing deficiencies were addressed and Wise developed a stronger enterprise-wide framework.

The regulator highlighted the proposed bank’s planned reliance on Wise US and other global affiliates for compliance operations. Because Wise processes high volumes of international payments, the OCC said the group’s controls would need to be proportionate to the scale and risk of the broader enterprise rather than limited to the proposed trust-bank subsidiary.

The agency concluded that the application did not adequately address key weaknesses in the proposed AML and counter-terrorist-financing risk-management program. It also noted that a national trust bank would face additional federal requirements beyond those governing Wise US in its current role as a money-services business.

The distinction is important for fintech companies seeking bank charters. A licensed money transmitter must comply with the Bank Secrecy Act, suspicious-activity reporting requirements and state supervision, but a federally chartered bank is subject to a broader set of governance, risk-management, fiduciary and supervisory obligations. The OCC must determine not only that a proposed institution has policies on paper, but also that its organizers and executives can operate the institution safely and consistently with national banking law.

The decision cited a July 2025 multistate consent order involving Wise US. State regulators identified deficiencies in areas including suspicious-activity investigations, transaction-monitoring data integrity, the timely filing of suspicious-activity reports, independent program reviews and the correction of previously identified weaknesses. Wise agreed to pay a $4.2 million administrative penalty and undertake corrective measures.

Under that settlement, Wise was required to strengthen its AML and counter-terrorist-financing program, use an independent third party to verify corrective work and provide quarterly reports to participating regulators for two years. The OCC said the enforcement action was important to its assessment, although such an order did not automatically determine the charter application’s outcome.

Wise said it has made extensive changes since the original application was prepared. The company reported strengthening its U.S. compliance program, improving investigation and reporting processes, increasing the integrity of customer data and adding resources to local compliance operations. It also said it had invested in global controls intended to prevent financial crime and other forms of risk.

The OCC nevertheless found that the application and the available supervisory record did not yet demonstrate that the proposed trust bank could satisfy the higher requirements applied to federally chartered institutions. The agency said Wise US had a record of failing to comply with requirements applicable to money-services businesses and that the submission did not establish that Wise National Trust could comply with the additional rules governing banks.

Management and board experience represented a separate obstacle. The OCC said the organizers did not demonstrate sufficient familiarity with national banking laws and regulations and had not selected directors and management officials with adequate AML and counter-terrorist-financing expertise. The regulator also questioned the group’s ability to manage the high inherent illicit-finance risks associated with the proposed services.

Fiduciary expertise was another area of concern. The proposed bank would have exercised trust powers, but the OCC said Wise US had no historical experience conducting fiduciary activities. It determined that the proposed management team and directors had not demonstrated sufficient knowledge of the laws and OCC regulations governing fiduciary services at national banks.

The agency ultimately concluded that the application presented significant supervisory and compliance concerns and would be inconsistent with its chartering policies. The denial also rendered moot Wise’s related requests for fiduciary powers and waivers from certain director residency and citizenship requirements.

The decision does not prevent Wise from applying again. The OCC explicitly said a future de novo charter application would be permitted, provided it satisfactorily addressed the reasons for the denial and met the statutory and regulatory criteria for establishing a national trust bank. Wise also retains the right to appeal the decision to the OCC’s ombudsman.

Rather than relying solely on an appeal, Wise indicated that it intends to submit a substantially updated application. The company said the business, its compliance capabilities and the U.S. regulatory environment have all changed since the original filing was submitted more than a year ago.

A major change involves the application’s original assumption that Wise National Trust would obtain direct access to a Federal Reserve master account. Such access could have enabled Wise to settle payments through Federal Reserve infrastructure rather than relying as extensively on correspondent banks. The OCC described the proposed charter as a way to create efficiencies, support future growth and allow Wise’s U.S. operations to scale more effectively.

Federal Reserve policy has since moved in a different direction. In May, the central bank proposed a new category of limited-purpose payment account intended to provide qualifying institutions with controlled access to certain Federal Reserve payment services. The proposed accounts would carry restrictions designed to limit credit, liquidity and illicit-finance risks and would not offer all the features of a conventional master account.

The Federal Reserve also encouraged regional Reserve Banks to pause decisions involving institutions classified in the highest-risk access category while the policy-development process continues. Wise said the original trust-bank plan became nonviable because it had been conditioned on direct master-account access and because access for an uninsured trust bank had effectively been paused.

The policy shift changes the strategic value of a trust charter for payments companies. A federal charter can provide regulatory consistency, national operating authority and an institutional framework for custody or fiduciary services, but it does not automatically guarantee access to Federal Reserve accounts. Charter applicants must therefore develop plans that remain commercially viable under more restrictive payment-access arrangements.

Wise said its next application would be structured under a framework reflecting the GENIUS Act, the recently enacted federal regime governing payment stablecoins. The company argued that its existing international payments network, treasury-management capabilities and risk controls could position it to connect traditional payment systems with regulated digital-asset infrastructure.

The company did not announce plans to issue its own stablecoin. Its statement instead emphasized interoperability, including the ability to connect different payment rails and provide infrastructure as stablecoins become more visible alongside conventional bank and card networks. A revised charter proposal could consequently focus on custody, reserve administration, settlement or other trust-bank functions compatible with the new federal framework.

That approach would still require Wise to satisfy the OCC that its financial-crime controls, governance and management experience are adequate. Stablecoin-related activities can introduce additional risks involving transaction traceability, reserve management, sanctions compliance, cybersecurity and connections between blockchain networks and the conventional banking system. The OCC’s decision indicates that an updated business model alone will not resolve the agency’s concerns without verifiable compliance remediation.

The rejection also has implications for the broader fintech sector. Payments companies have long sought alternatives to the fragmented state-by-state licensing structure and dependence on sponsor banks or correspondent institutions. A federal trust charter can offer operational advantages, but the Wise case demonstrates that regulators will examine the compliance record of the wider corporate group when a proposed bank depends heavily on affiliated technology, personnel and control systems.

Applicants cannot isolate a newly created banking subsidiary from weaknesses elsewhere in the enterprise when shared infrastructure is central to the business plan. The OCC’s analysis linked the viability of Wise National Trust directly to Wise US and the group’s global compliance organization, establishing that enterprise-wide maturity is a central consideration for large international fintech platforms pursuing federal charters.

The decision arrived shortly after Wise expanded its presence in U.S. capital markets through a Nasdaq listing. Investor reaction was negative, with its London-listed shares falling about 10% during July 24 trading. The decline reflected concern that the denial could delay infrastructure efficiencies and strategic options in the United States, although the company stressed that current revenue-generating operations were unaffected.

Wise has substantial scale with which to pursue a revised strategy. In fiscal 2026, the company served approximately 19 million consumers and businesses and processed more than $240 billion in cross-border transactions. Its products allow customers to hold more than 40 currencies, make international transfers, spend through debit cards and access Wise infrastructure through banks and corporate platforms.

The U.S. remains strategically important because of the size of its consumer-remittance, business-payment and financial-institution markets. Bringing more payment functions onto proprietary infrastructure could improve settlement speed, lower third-party costs and give Wise greater control over service development. The OCC’s action delays that objective but does not eliminate it.

The next application will probably need to document completed remediation rather than rely primarily on planned improvements. It will also need to demonstrate that proposed executives and directors possess direct experience with national banking law, bank-level AML obligations and fiduciary operations. A revised plan must account for the Federal Reserve’s changing access model without assuming that a charter will produce unrestricted central-bank connectivity.

Wise’s immediate challenge is therefore both regulatory and operational. It must continue expanding its U.S. payments business under the existing state licensing framework while proving that its controls have matured sufficiently for federal supervision. The company’s decision to reapply signals that it still views a national trust bank as strategically valuable, particularly as traditional and digital payment networks become more closely connected.

For the OCC, the denial reinforces that support for financial innovation does not remove longstanding chartering requirements. Payments technology, stablecoin legislation and new Federal Reserve account structures may broaden the range of institutions seeking federal oversight, but applicants must still demonstrate effective compliance, experienced management and a credible ability to operate safely from the outset.

The timetable for Wise’s new filing remains uncertain. The company said it would submit a viable application “in due course” and characterized its relationship with the OCC as positive. Until a revised proposal is filed and reviewed, Wise will continue operating through its current licenses while the market evaluates whether its compliance investments can convert a high-profile rejection into a future approval.