Wise plans to refile for a national trust bank charter under the GENIUS Act after the OCC rejected its first bid over AML and CFT compliance failures. The company faces a moving regulatory target with implementation guidelines still unfinished.
Wise is going back to the drawing board. The cross-border payments company plans to file a new national trust bank charter application under the GENIUS Act framework, after the U.S. Office of the Comptroller of the Currency shot down its first attempt over anti-money laundering and counter-terrorism financing failures.
The OCC's rejection was blunt. The agency cited Wise's inadequate compliance with Anti-Money Laundering and Countering the Financing of Terrorism regulations – AML and CFT, in the shorthand that compliance teams live by – as the core reasons for the denial. Broader concerns about illicit finance activity risks also figured. No details on exactly what triggered those concerns. Wise itself has not publicly spelled out which specific programs fell short, and the company has yet to comment on what concrete changes it plans to make before resubmitting.
The GENIUS Act became law in July 2025. It lays out a regulatory framework for payment stablecoin providers operating in the U.S., aiming to standardize compliance and operational requirements across the sector. Federal regulators have already missed their deadline to finalize implementation guidelines. Full implementation is not expected until January 2027 at the earliest, pending that regulatory guidance. Wise is aiming at a moving target. The framework exists on paper, but the detailed rulebook is not done yet.
That ambiguity cuts both ways. It is harder for Wise to know exactly what box to check. But it also means the OCC probably can not hold an applicant to rules that have not been written yet, which might give Wise some room to maneuver on the resubmission.
William Blair, the investment banking group tied to Wise, said the company's position on payment stablecoins is unchanged despite the rejection. Wise's core mission stays the same: cut costs in cross-border transactions, whatever infrastructure ends up carrying that load. Stablecoins are a means to an end, not the end itself. That framing suggests Wise will not dramatically pivot its business model – it will try to fix the compliance side of the equation.
While Wise got turned away, the OCC has been active on the approval side for other digital asset companies. Circle, Ripple Labs, Crypto.com and Coinbase have all received national trust charters recently. All four approvals came after the stablecoin bill passed. The OCC is open to digital asset firms, but compliance is the filter.
Wise now has to look at those four companies and figure out what they did differently. AML and CFT programs are not fixed overnight. Building out transaction monitoring systems, updating customer due diligence protocols, training staff, bringing in outside compliance consultants – it is expensive and slow. Wise has to do all of this while the GENIUS Act's final rules are still being written.
Getting rejected by the OCC for AML deficiencies is the kind of thing that makes institutional partners nervous. Cross-border payments is a trust business. Wise has built a strong retail brand, but the OCC rejection is a speed bump it will need to explain to corporate clients and banking partners.
The path forward is clear in broad strokes, even if the details are murky. Wise needs to overhaul whatever compliance frameworks the OCC found lacking, demonstrate that its AML and CFT programs meet the agency's standards, and do all of that before the GENIUS Act implementation guidelines are finalized – or be ready to pivot quickly once those guidelines drop.
The absence of finalized GENIUS Act rules creates uncertainty for the resubmission strategy. Wise can not fully calibrate its application to rules that do not exist yet. What it can do is address the specific gaps the OCC already flagged, because those presumably apply regardless of whatever the final implementation guidelines say.
Timing matters. If Wise gets its compliance act together and resubmits before January 2027, it could be positioned well as the GENIUS Act framework clicks into place. If it drags its feet, it risks losing ground to Circle, Coinbase and the others who already hold charters.
Wise has not set a public timeline for the resubmission.
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