The OCC denied Wise’s application for a national trust bank charter in Corporate Decision #1381, dated July 21, 2026. The agency said it could not conclude the proposed bank would run an effective AML/CFT compliance program in the United States, citing the multistate order under which Wise US agreed to a $4.2 million penalty. Wise has said it will apply again under a GENIUS Act framework.

What the decision says

The outcome is one line: “the OCC denies the Application.” The bank Wise proposed would have offered U.S. customers “stored value accounts with debit cards”, called multi-currency accounts (MCA) in the application, plus payments processing and fiduciary services, according to Corporate Decision #1381.

The reason the OCC gives is the compliance record behind the application. The decision records that Wise US “agreed to pay an administrative penalty of $4.2 million” divided equally among the participating regulators, and says the agency “cannot conclude” the proposed national trust bank will have “an effective AML/CFT compliance program” for conducting business in the U.S.

What Wise says

In a statement to the market on July 24, 2026, Wise said it plans to submit “a new application for a national trust bank charter” under a GENIUS Act framework. The company also said its original application “was conditioned on obtaining direct access to master accounts” at the Federal Reserve.

What it means for charter applicants

A denial is unusual in the current wave of trust charter applications, and this one turns on the group’s supervisory history rather than the mechanics of the business plan. Two points follow for payments companies weighing a charter of their own. A settled enforcement matter at an affiliate is evidence the OCC weighs when it judges whether the proposed bank can run a compliance program. And a plan whose account structure depends on direct access to a Federal Reserve master account carries a second approval the charter decision does not deliver.

For companies that keep running on partner banks meanwhile, our explainer on embedded finance vs banking as a service sets out the two routes, and how to choose a sponsor bank covers the diligence involved.

What to watch

Wise gives no date for the new application, and the decision sets no deadline or route for reconsideration. The company has named the GENIUS Act framework as the basis for its next filing. Later charter decisions appear in payments news.