Wise pivots to GENIUS Act after OCC rejects U.S. trust-bank charter
Payments firm Wise said it will refile for a U.S. national trust bank charter under the GENIUS Act after the Office of the Comptroller of the Currency (OCC) denied its first application. The OCC’s July 21 decision halted Wise’s plan to create Wise National Trust in Austin, Texas; Wise disclosed the outcome on July 24 and said its U.S. operations continue unchanged through money-transmitter licences in 48 states and four territories.
Why the OCC said no
- The OCC concluded Wise had not demonstrated that the proposed trust bank could meet U.S. legal and regulatory requirements.
- Regulators highlighted weaknesses in anti-money-laundering (AML) and countering the financing of terrorism (CFT) controls and pointed to a record of compliance shortfalls by Wise U.S. under money-services rules.
- The OCC also criticized the governance plan, saying proposed directors and managers lacked sufficient experience with national banking rules, fiduciary services, and AML/CFT operations.
- The proposed trust bank’s heavy reliance on Wise U.S. and other group companies for compliance work was another concern.
The OCC noted that approval would conflict with its charter policies but left the door open for a new application once issues are addressed.
Wise’s response and strategic shift
- Wise said it has strengthened financial-crime controls since its June 2025 filing and intends to address the OCC’s findings in a revised submission. The company’s London-listed shares fell as much as 10% after the denial became public.
- Separately, Wise said a practical driver of the change in approach was the Federal Reserve’s effective pause on account access for uninsured trust banks while the Fed develops a new payment-account policy. “With the Federal Reserve generally pausing account access for an uninsured trust bank, the approach in our application became non‑viable,” Wise said. The original plan aimed to let Wise settle U.S. dollar payments more directly and reduce reliance on partner banks.
Why GENIUS Act — and what Wise will need to show
- Wise plans to refile using the GENIUS Act federal framework for payment stablecoins rather than its original model. It has not said it will issue its own stablecoin. Analysts at William Blair say Wise remains “agnostic of the rail,” focused on cutting cross-border costs whether using traditional rails or digital assets.
- The GENIUS Act (enacted July 2025) creates a federal licensing and supervision regime for payment stablecoin issuers, setting reserve, redemption, reporting, consumer-protection, and compliance requirements. The law takes effect on January 18, 2027, or 120 days after regulators publish final rules, whichever comes first.
- Key rule details remain unresolved: the OCC published a main proposed rule in March and the Treasury proposed AML and sanctions standards, but regulators missed a July 18 rulemaking deadline. Final rules were still pending when Wise announced its new plan.
- In any GENIUS Act application Wise must explain the new entity’s activities, how it would use stablecoins (if at all), how it will meet the enhanced AML/CFT standards envisioned for permitted issuers, and how the charter would function without the unrestricted Federal Reserve access assumed in the earlier model.
Regulatory context and competition
- The OCC has recently moved several digital-asset firms through the national trust-charter process. Circle received final approval in July 2026 after conditional approval in December; Ripple, Paxos, BitGo, Fidelity Digital Assets, Crypto.com, Bridge, and Coinbase have also received conditional decisions or entered the process.
- These approvals have faced pushback from banking groups and some lawmakers — for example, the Bank Policy Institute has considered legal challenges to the OCC’s trust-charter policy. Wise’s situation is distinct because the OCC issued a direct denial tied to its compliance record and management plan, rather than granting conditional approval.
What’s next
Wise will need to satisfy the OCC’s standards in a reworked application under the GENIUS Act. That means concrete fixes to AML/CFT controls, stronger governance credentials, and a clear operational model that does not depend on unrestricted Federal Reserve account access for an uninsured trust bank. Regulators’ forthcoming rule decisions will also shape the timeline and requirements for any stablecoin-related filing.
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