OCC denies Wise a national trust charter and faults the people named to run it

What happened

The US Office of the Comptroller of the Currency, the OCC, has denied Wise’s application to establish a national trust bank. Banking Dive reported the decision on 24 July 2026 and quoted the OCC’s letter at length. The letter is signed by Stephen Lybarger, the OCC’s senior deputy comptroller for chartering, organization and structure, and addressed to Satyan Melwani, Wise’s head of North America banking and expansion.

The OCC letter, quoted by Banking Dive, says the application “presents significant supervisory and compliance concerns”. It states that Wise US “has been in continuing noncompliance” with federal anti-money laundering and countering the financing of terrorism requirements (AML/CFT), and that the organizers are “part of long-standing AML/CFT deficiencies at Wise US”.

Banking Dive, quoting the letter, reports that the organizers “failed to select appropriate directors and management officials with sufficient experience” with AML/CFT requirements or with fiduciary activities. The proposed leaders, the letter says, “have demonstrated a persistent inability to sufficiently manage” money laundering and illicit finance risks tied to the proposed bank’s activities.

The sequence matters. In July 2025, less than a month after the application went in, Wise’s US arm was hit with a multistate consent order over Bank Secrecy Act, AML and CFT programme deficiencies, according to Banking Dive. Wise US agreed to pay USD 4.2 million and increase its compliance investment. California regulators issued a separate order. This is a chartering decision, not an enforcement action. The OCC said the denial does not preclude a further application, which it would expect to “satisfactorily address the reasons for this action”. Wise says its business and compliance maturity “have evolved significantly” and that it intends to file a new application under a Genius Act framework.

Why it matters

Read as analysis, the useful lesson here is about how long a consent order lives. Wise US paid, agreed to remediate, and still lost the charter roughly a year later. The order did not close when the money moved.

Carl Goss, a Dallas-based partner at Hunton Andrews Kurth and a former OCC lawyer, told Banking Dive that once the multistate order landed, a denial “would have been pretty much a foregone conclusion”. He added that “it’s difficult to act favorably on an application if there are even large alleged issues with AML”. The OCC’s own letter is more measured, per Banking Dive: enforcement actions are “important to, but do not ultimately control,” its application decisions.

The sharper signal, on this reading, is that the reasoning targeted people rather than documentation alone. The regulator treated the choice of directors and management officials as a supervisory finding in its own right. Rebuilding a monitoring rule set is a project with a delivery date. Proving your named leadership carries credible AML/CFT and fiduciary experience is a governance decision, and it is far harder to retrofit under application deadlines.

Practitioner angle

• Pull your licensing and permissions pipeline now. List every charter, licence, passport, e-money permission, bank partnership, and correspondent onboarding your firm expects to file in the next 24 months, then map each open or recently settled AML finding against it.
• Rewrite the disclosure narrative before a regulator asks. For each past order, state the deficiency, the remediation, the evidence of effectiveness, and the residual gap. Vague assurance of maturity is what gets tested hardest.
• Pressure-test your key-person bench against the standard the OCC applied: named directors and senior managers with demonstrable AML/CFT and product-specific regulatory experience, evidenced in the file, not asserted in a covering letter.
• Check whether your proposed leadership for any new entity has changed since filing. Stale organizer detail is an avoidable credibility problem.

Take one thing to the board this quarter: an AML consent order is not a closed cost line once paid, it is a standing fact about the firm that follows every future application, so fund remediation and leadership hiring as strategic access, not clean-up.