OCC Rejects Wise’s US National Trust Bank Charter Over AML Risk as Crypto Firms Win Approvals

The OCC has denied Wise’s application for a US national trust bank charter over money-laundering risk concerns — a rare rejection that lands just weeks after the regulator greenlit a wave of crypto-firm charters, including conditional approvals for XXRP$1.09▼1.80% and at least four other digital asset companies.

Wise filed on or around June 16, 2025. It wanted to charter a national nondepository trust bank under the name Wise National Trust, NA (WNT), according to the OCC’s public comment document. The proposed entity was built to run multi-currency accounts and payment processing — activities that critics who weighed in during the comment period argued stretched well beyond what a national trust charter was ever meant to cover.

The contrast is stark. On December 12, 2025, the regulator conditionally approved national trust bank charters for at least five firms, including Ripple and First National Digital Currency Bank. Circle separately won a federal trust bank charter from the OCC. So here’s the picture: a London-based payments company with years of cross-border money-movement experience gets flagged for anti-money-laundering risk while crypto-native firms clear the same process without a hitch. That has drawn scrutiny across the banking industry — and not only from Wise’s corner.

The Bank Policy Institute pushed back. It filed a comment letter on October 14, 2025 opposing the application, arguing that WNT sought to engage in banking activities that are “neither those of a bona fide trust.” Its objection was structural, not competitive. The trade group questioned whether the national trust charter — a vehicle historically reserved for fiduciary and custodial services — was being repurposed as a shortcut to payment-system access, one that would sidestep the full supervisory burden of a commercial bank charter. And that same structural argument? It applies with equal force to several of the crypto firms the OCC went ahead and approved.

The Independent Community Bankers of America piled on. Its letter of opposition dated July 18, 2025 argued that granting Wise a national trust charter would tilt the playing field. Community banks face full-scope examinations and capital requirements that a limited-purpose trust charter sidesteps entirely — and the ICBA made clear it saw no reason to extend that shortcut to a foreign payments firm.

A Deeper Inconsistency

Deny Wise, approve the crypto firms. That decision exposes a deeper inconsistency in how the regulator is applying its trust charter authority. The Conference of State Bank Supervisors has separately criticized the OCC’s final trust charter rule, issued February 27, 2026, saying it “fails to address” key concerns. The CSBS criticism is a signal that the state-federal turf war over who regulates nontraditional financial institutions is far from settled. State regulators have long argued the OCC is overstepping its statutory mandate by granting national charters to entities that don’t engage in traditional deposit-taking or fiduciary trust business.

Legal scholars have gone further still. A 2026 George Washington University law review article argues the OCC has violated four federal statutes through its national trust bank charter approvals, flagging what the authors describe as “grave and intolerable risks to US financial stability.” The article doesn’t name Wise specifically. But it frames the broader charter-approval spree as legally precarious — and potentially vulnerable to litigation from parties who believe the OCC has exceeded its congressionally granted authority.

Wise’s Next Move: The GENIUS Act

Wise is not walking away from the US market. The company plans to refile its charter application under the GENIUS Act — the stablecoin legislation currently moving through Congress. Whether that legislative pathway offers a cleaner route to federal oversight than the contested trust charter process depends heavily on the final shape of the bill as it moves through reconciliation and amendment.

The market context adds a layer of irony. XRP — the token tied to Ripple, one of the firms that secured OCC charter approval — is currently trading at $1.09, down 1.4% over the past 24 hours, with a market cap of $67.87 billion. The broader crypto market sits at $2,276.88 billion, off 0.78% in 24 hours. The Fear & Greed Index reads 28 — firmly in fear territory. Investors are not pricing in any regulatory tailwind from the charter approvals, or macro headwinds are simply overwhelming whatever sector-specific optimism the OCC news might otherwise generate.

For Wise, the immediate question is whether the GENIUS Act route will be faster than appealing the OCC’s decision directly. For the OCC, the harder question is how it justifies denying a regulated payments company on AML grounds while extending trust charters to firms whose core business involves digital assets that have, at various points, sat at the center of some of the largest money-laundering cases in recent memory.

The next concrete marker: whether Wise files under the GENIUS Act before the bill reaches a floor vote, and whether the OCC faces a formal legal challenge to its trust charter authority from state regulators or banking trade groups before that happens.