Wise’s National Trust Bank Charter Application
Wise is poised to reapply for a national trust bank charter in the U.S. after its initial request was declined by the Office of the Comptroller of the Currency (OCC). This rejection occurred on July 21, 2023, halting the company’s ambitions to establish Wise National Trust in Austin, Texas. However, Wise reassured its users that operations within the U.S. will remain unaffected, as it continues to function under money transmitter licenses across 48 states and four territories.
Future Plans and Compliance Strategy
The announcement of the OCC’s decision came shortly before Wise outlined its future plans on July 24, including a shift in its application strategy toward compliance with the GENIUS Act, which governs payment stablecoins at the federal level.
The initial application, lodged in June 2025, relied on obtaining access to the Federal Reserve’s payment systems, a strategy that has since been deemed unfeasible. Post-rejection, Wise saw its shares decrease by as much as 10%, highlighting investor concerns over the firm’s compliance practices.
Regulatory Feedback and Improvements
In light of the feedback from the OCC, which flagged deficiencies in Wise’s anti-money laundering (AML) and counter-terrorist financing (CFT) measures, the company noted improvements in its financial crime controls and expressed commitment to addressing these issues in its upcoming submission.
The OCC found that Wise had not adequately demonstrated its capability to comply with U.S. regulatory and legal requirements for its proposed bank, citing specific weaknesses in crucial areas such as compliance and governance. There were also doubts raised regarding the qualifications of the proposed bank’s management team, as the OCC found potential gaps in their knowledge of national banking regulations, fiduciary duties, and compliance with AML/CFT laws.
Leveraging the GENIUS Act
In its latest strategy, Wise intends to leverage the GENIUS Act, which was enacted in July 2025 and outlines stringent requirements for payment stablecoin issuers regarding reserves, consumer protection, and compliance. Although Wise has not indicated plans to launch its own stablecoin, this legislative move allows the firm more structured access to national banking frameworks.
Analysts from William Blair have stated that they do not anticipate significant changes in Wise’s strategic direction, noting that the company aims to minimize costs associated with international payments, regardless of whether the transactions utilize traditional methods or digital currencies.
Challenges Ahead
Despite the challenges, including the Federal Reserve’s current pause on account access for uninsured trust banks which has made previous plans untenable, Wise is determined to navigate the review process for the new filing. The GENIUS Act is expected to be operational by early 2027, although some essential regulatory details are still being finalized.
Other companies like Circle, Ripple, and Coinbase have successfully initiated or received varying degrees of approval under similar frameworks, showcasing the competitive landscape Wise is now entering.
As Wise prepares to file its new application, it must clearly articulate its operational model, the role of stablecoins, and how it will comply with the enhanced AML/CFT standards set forth by regulators to secure a national charter.
