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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 wasn’t subtle. 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 regulators and compliance teams live by — as the core reasons for the denial. There were also broader concerns about illicit finance activity risks. No details on exactly what triggered those concerns. Wise itself hasn’t 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. That silence is notable, honestly. Other applicants that got through presumably had their compliance houses in better order from the start.
Not a complete surprise, though.
What the GENIUS Act Actually Does Here
The GENIUS Act became law in July 2025. It lays out a regulatory framework specifically for payment stablecoin providers operating in the U.S., trying to standardize what compliance and operational requirements look like across the sector. But here’s the catch — federal regulators have already missed their deadline to finalize the implementation guidelines. Full implementation isn’t expected until January 2027 at the earliest, pending that regulatory guidance. So Wise is basically aiming at a moving target. The framework exists on paper, but the detailed rulebook isn’t done yet.
That ambiguity cuts both ways. It’s harder for Wise to know exactly what box to check. But it also means the OCC probably can’t hold an applicant to rules that haven’t 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 pretty much 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 matters because it kind of suggests Wise won’t dramatically pivot its business model — it’ll just try to fix the compliance side of the equation.
OCC Already Said Yes to Circle, Ripple, Coinbase, Crypto.com
While Wise got turned away, the OCC has been fairly active on the approval side for other digital asset companies. Circle, Ripple Labs, Crypto.com, and Coinbase have all recently received national trust charters. All four approvals came after the stablecoin bill passed, which tells you something about the regulatory mood right now — the OCC is open to digital asset firms, but it’s not handing out charters to anyone who asks nicely. Compliance is the filter, and it’s a real one.
Wise now has to look at those four companies and figure out what they did differently. That’s not a small task. AML and CFT programs aren’t fixed overnight. Building out transaction monitoring systems, updating customer due diligence protocols, training staff, maybe bringing in outside compliance consultants — it’s expensive and slow. And Wise has to do all of this while the GENIUS Act’s final rules are still being written.
There’s also a reputational dimension worth mentioning. 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’ll need to explain clearly to corporate clients and banking partners.
Hard to say how long the resubmission process takes.
What Wise Needs to Fix Before Reapplying
The path forward for Wise is pretty clear in broad strokes, even if the details are murky. It 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’s implementation guidelines are finalized — or at least be ready to pivot quickly once those guidelines drop.
The absence of finalized GENIUS Act rules creates genuine uncertainty for the resubmission strategy. Wise can’t fully calibrate its application to rules that don’t 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 here. 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 and will be operating under the new rules from day one.
The stablecoin market in the U.S. is moving fast. Regulatory access is probably the single biggest competitive advantage right now, and Wise knows it. Getting that national trust bank charter isn’t optional if the company wants to stay relevant in U.S. dollar-denominated payment flows.
Wise hasn’t set a public timeline for the resubmission.
Frequently Asked Questions
Why did the OCC reject Wise’s charter application?
The OCC rejected Wise’s application due to inadequate compliance with Anti-Money Laundering and Countering the Financing of Terrorism regulations, along with concerns about illicit finance activity risks.
Which companies has the OCC recently granted national trust charters to?
The OCC has recently granted national trust charters to Circle, Ripple Labs, Crypto.com, and Coinbase, all following the passage of the GENIUS Act stablecoin legislation.
