Payments company Wise said it will reassess its application strategy with the US Office of the Comptroller of the Currency (OCC) after the regulator rejected its effort to become a national trust bank.

In a notice issued Thursday, Wise said it intends to submit a new application under a “GENIUS Act framework,” referring to US legislation designed to create a regulated pathway for payment stablecoin activities. The decision follows the OCC’s denial of Wise’s original national trust bank charter application, which the agency rejected on Tuesday.

The OCC’s decision is significant because Wise’s initial charter strategy has now been formally denied, while the GENIUS Act is intended to provide clearer rules for stablecoin issuers and payment providers once implementing regulations are finalized. Wise’s revised approach may also be relevant for other fintech companies evaluating stablecoin-related business models in the United States.

Wise shifts application strategy after OCC rejection

The OCC denied Wise’s national trust bank charter application on Tuesday. In its rejection, the agency said Wise had not demonstrated that it maintained an effective anti-money laundering and countering the financing of terrorism program, commonly referred to as AML/CFT. The regulator also cited “other illicit finance activity risks” as part of the basis for refusing the application.

Rather than end its pursuit of a banking charter, Wise said it plans to change how it structures its application. According to a notice published on Wise’s investor relations platform, the company intends to file a new national trust bank charter application under a “GENIUS Act framework,” linking the proposal more directly to the US statute governing certain payment stablecoin activities.

Investment banking group William Blair said the procedural shift is not expected to change Wise’s broader position on payment stablecoins. According to William Blair’s reporting on the move, Wise remains focused on reducing the cost of cross-border transactions, “agnostic of the rail.”

Wise has built its business around international payments and cross-border money transfers. The company’s proposed charter was tied to its use of stablecoin-related rails, according to the source material, but the OCC’s denial focused on compliance readiness and illicit-finance risk controls.

GENIUS Act creates a stablecoin framework, but rules remain pending

The GENIUS Act, signed into law in July 2025, is intended to establish a clearer regulatory pathway for payment stablecoin providers in the United States. The law provides a framework for oversight of stablecoins used in payments, while leaving additional regulatory steps to be completed before full implementation.

Operational details remain unsettled. Cointelegraph previously reported that federal agencies missed a key deadline to issue guidance on how the GENIUS Act should be implemented before its effective date in January 2027. As a result, even though the law is now in place, companies may still face uncertainty over how regulators will interpret and apply its requirements in practice.

Wise’s plan to refile under the GENIUS Act framework highlights a practical issue for companies operating near the intersection of payments, banking supervision and stablecoin infrastructure. Firms may seek to align their applications with forthcoming stablecoin rules, but they must also meet established supervisory expectations for banking charters, particularly in areas such as AML/CFT controls, illicit-finance monitoring and risk management.

OCC compliance concerns remain central

The OCC’s stated reasoning for denying Wise’s original application centered on compliance readiness. The agency said Wise failed to show that it had an effective AML and CFT compliance program and also pointed to other illicit finance activity risks.

Those concerns remain important even if Wise proceeds with a revised filing under the GENIUS Act framework. A stablecoin-focused statute does not remove the OCC’s requirement that national trust bank charter applicants demonstrate adequate compliance systems and risk controls.

Wise therefore faces two related requirements in any renewed application: aligning its payment stablecoin strategy with the GENIUS Act while also satisfying the OCC’s supervisory standards for money laundering, terrorist financing and broader illicit-finance risk management.

The revised framework may affect how Wise organizes and presents its application, but the OCC’s denial indicates that the agency’s assessment of compliance systems will remain a central factor. Investors, partners and other industry participants are likely to focus on how Wise addresses the specific AML/CFT and illicit-finance concerns identified by the regulator.

OCC has approved some digital asset charter applications

Following passage of the stablecoin legislation, the OCC has approved several applications for national trust charters from major digital asset firms, including Circle, Ripple Labs, Crypto.com and Coinbase, according to earlier reporting referenced in the source material. Those approvals indicate that the OCC has been processing charter requests in the post-stablecoin-bill environment.

At the same time, Wise’s denial shows that not all applicants receive approval on the first attempt, particularly when regulators identify weaknesses in AML/CFT effectiveness or other illicit-finance controls. The distinction between approved applications and Wise’s rejected bid may depend on the OCC’s assessment of risk controls, compliance readiness and supervisory expectations.

For payment companies and stablecoin-adjacent businesses considering US expansion, the situation underscores the importance of both policy alignment and regulator-reviewed compliance infrastructure. Companies may structure products and applications around GENIUS Act expectations, but the OCC’s decision indicates that compliance architecture remains a decisive part of the charter process.

As Wise prepares a new filing, attention will likely center on how the company documents its AML/CFT program and responds to the “illicit finance activity risks” cited by the OCC. Final GENIUS Act regulations are still pending, and federal guidance has already been delayed relative to the law’s effective date. Those implementation details will shape how the framework is applied to future applicants and what additional assurances regulators may require.