The Office of the Comptroller of the Currency denied Wise’s application for a national trust bank charter this week, and the letter reads like an indictment.
Stephen Lybarger, the OCC’s senior deputy comptroller for chartering, wrote that Wise’s application “presents significant supervisory and compliance concerns” and that its proposed leadership failed to show “sufficient familiarity” with federal banking law, according to the OCC’s decision letter. Organizers “collectively failed to demonstrate sufficient experience” with fiduciary activities, and Wise US “has been in continuing noncompliance” with anti-money-laundering rules.
The timing explains the reasoning. A month after Wise filed its charter application in June 2025, state regulators hit Wise US with a multi-state consent order over Bank Secrecy Act and AML failures, extracting $4.2 million and a compliance overhaul. Lybarger noted enforcement actions don’t automatically control chartering decisions. Here, they did.
This is the first denial the OCC has issued amid the current wave of charter applications under the second Trump administration, which makes it a marker, not just a rejection. That the OCC would issue its first denial here, rather than approve and let compliance catch up later, signals AML history is now a hard gate, not a factor to be weighed against growth ambitions.
Wise isn’t backing off. The company said Thursday it will refile under a GENIUS Act framework, arguing its compliance program has “evolved significantly” since last year’s application. One outside lawyer’s advice was blunter: swap out the management team before trying again.
The denial doesn’t bar a second attempt, but the OCC made clear any refiling needs to fix what this one didn’t. No deadline yet on when that lands.
— James Okafor