How Wise's OCC rejection creates demand for bank AML experts

• Key insights: The Office of the Comptroller of the Currency denied Wise's application to charter a de novo national trust bank, citing deficiencies in the company's Bank Secrecy Act, Anti-Money Laundering and Countering the Financing of Terrorism programs.  
• What's at stake: The decision marks the OCC's first public denial of a fintech's charter application following the approval of more than two dozen charter applications this year. 
• Forward look: Wise said it intends to submit a new application for a national trust bank charter under a GENIUS Act framework. 

In a rare move, the Office of the Comptroller of the Currency denied Wise's application to charter a de novo U.S. national trust bank, citing deficiencies in the company's Bank Secrecy Act, Anti-Money Laundering and Countering the Financing of Terrorism program. 

The OCC's decision marks the regulators' first public denial of a fintech's bank charter application following the approval of more than two-dozen charter applications, and signals to other cryptocurrency firms and fintechs seeking to obtain a coveted banking charter that the OCC is paying close attention to AML and CFT capabilities — and the people put in place to run them — even at a time when wider pressure from federal regulators has abated. 

For banks, it's a sign that competition for risk-based talent continues to heat up, according to Adam Eckels, CEO and founder of AJ Consultants, an executive recruitment firm that specializes in the banking and fintech industries. 

"Fintechs are trying to nab some bank talent to get their bank charters off the ground," Eckels told American Banker. "Banks are held to different regulatory standards, obviously, than a fintech. If a fintech wants to become a bank … they can't just get somebody that talks a big game when it comes to risk. They have to get somebody that's walked the walk before." 

Wise, which submitted its application last year, had planned to use the charter to offer multicurrency accounts with debit cards and fiduciary services to U.S. customers and payment processing to direct customers, domestic and foreign affiliates, and other companies, including financial institutions. 

But Wise has been under pressure by regulators to improve its AML and CFT program. Early last year, the Consumer Financial Protection Bureau ordered Wise to pay $2.5 million for illegal remittance practices, and later that year a coalition of six state regulators hit the fintech with a $4.2 million consent order for its compliance program. The company is part of an investigation in Belgium for suspected money laundering on its platform tied to drug trafficking, fraud and corruption.

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"Since submitting this original application over a year ago, our business and compliance maturity have evolved significantly," Wise said in a 6-K filing with the Securities and Exchange Commission. "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." 

A spokesperson for Wise declined to comment further on the decision. 

The OCC in its denial said that "significant enforcement actions such as these are important to, but do not ultimately control, the OCC's decisions with respect to charter applications. 

"Wise US has a record of failing to comply with the applicable [money service business] requirements," the OCC said. "The fact that the organizers failed to select appropriate directors and management officials with sufficient experience with AML/CFT requirements and operations did not reflect favorably on the application." 

Wise said it intends to submit a new application for a national trust bank charter under a GENIUS Act framework. 

A bank charter from the OCC was the first step in gaining direct access to master accounts at the Federal Reserve, Wise's ultimate endgame. But that plan was complicated with the Federal Reserve's proposed May 2026 changes to its so-called skinny master accounts.  

"Our original application was conditioned on obtaining direct access to master accounts at the Federal Reserve," Wise said in the filing. "With the Federal Reserve generally pausing account access for an uninsured trust bank, the approach in our application became non-viable. 

"Regulation for payments in the U.S. has also changed significantly in the last year, including the enactment of the GENIUS Act, along with rapidly evolving Federal Reserve policy on how financial institutions can directly access the federal payments network," Wise said. 

Shares of Wise were down 5.7%, or 69 cents, to $11.39 as of 2:52 p.m. in New York.    

The news, while disappointing, should have minimal impact on Wise's operations in the U.S., which continues to be a "meaningful and growing market for the company," according to William Blair analyst Cristopher Kennedy. Wise's U.S. net revenue increased 15% year over year for its fiscal 2026, compared with 9% in its fiscal 2025.