Summary
The OCC's denial of Wise's national trust bank charter (Corporate Decision #1381, July 21, 2026) is the first public denial of a fintech charter under the current administration. The OCC cited a "persistent inability" to manage AML/CFT risks, referencing a $4.2M multistate consent order and an ongoing Belgian investigation into €500M+ in suspicious transactions. Wise plans to refile under the GENIUS Act's PPSI framework, but the OCC's proposed Part 15 regulations estimate a $15M annual compliance floor — suggesting the GENIUS Act will not serve as a regulatory back door.
Key Points
- First public fintech charter denial under current administration (2+ dozen previously approved)
- OCC cited "persistent inability" to manage AML/CFT risks
- $4.2M multistate consent order (July 2025); Belgian investigation into €500M+ suspicious transactions
- Wise operates under money transmitter licenses in 48 states + 4 territories
- Wise filed to refile under GENIUS Act PPSI framework (July 23)
- OCC proposed Part 15 regulations: ~$15M annual compliance floor for GENIUS Act issuers
- Contrast: Circle secured full OCC charter (July 10); Augustus conditional approval (May 2026)
- Fed's pause on account access for uninsured trust banks made original model non-viable
- Key lesson: "growth at all costs" ethos retired; "compliance-first" regime in place
- Cost of entry: not just capital, but demonstrated ability to police your own ecosystem