Wise Faces Class Action and OCC Trust Bank Denial, Pivots to GENIUS Act Stablecoin Path
Wise faces a securities class action over alleged AML risk disclosures as the OCC's rejection of its U.S. trust-bank plan forces a GENIUS Act refile and keeps its direct-payments-rail ambitions on hold.
Wise is confronting a new securities class action as its U.S. banking plan is forced back to the drawing board. A New York complaint alleges that the cross-border payments group and two senior executives understated anti-money-laundering and counter-terrorist-financing risks before Nasdaq trading, adding litigation to the Belgian criminal probe and rejected U.S. trust-bank bid.[1]
The proposed class covers investors who bought Wise Group plc securities from May 11 through July 23, 2026. It names Wise, Chief Executive Officer Kristo Käärmann and Chief Financial Officer Emmanuel Thomassin; the claims have not been proven. The complaint was filed July 31 in the U.S. District Court for the Southern District of New York, and investors seeking to lead the putative class must move by September 29, 2026.[1]
A Listing Narrative Meets Two Regulatory Disclosures
The lawsuit reaches back to Wise's Nasdaq move. Its Form 20-F became effective May 8, and trading began May 11 after the primary-listing transfer. Plaintiffs allege Wise treated regulatory exposure as a general risk despite the Belgian investigation and U.S. charter concerns.[1]
That allegation puts two later events at the center of the case. On June 1, reporting disclosed a Brussels Public Prosecutor's Office investigation involving more than €500 million in suspicious transactions. Prosecutors said the inquiry, which began in 2025, was nearing completion and that a direct criminal-court summons was being finalised; Wise said it was cooperating and had not been given specific findings.[5] Wise shares fell as much as 19 percent intraday in the initial market reaction, a reversal that has become the factual anchor of the investor claim.
The complaint also points to the OCC decision that emerged in late July. It alleges that Wise had materially understated the risk that the U.S. regulator would reject its national trust-bank application because of AML and counter-terrorist-financing weaknesses. The complaint seeks damages under Sections 10(b) and 20(a) of the Securities Exchange Act and SEC Rule 10b-5. Those are assertions by the plaintiff, not findings by a court or regulator.[1]
Date — Wise 2026 timeline — Why it matters
May 8 — Form 20-F registration statement effective — Preceded the Nasdaq trading start cited in the complaint
May 11 — Primary listing transfer to Nasdaq; trading begins — Start of the proposed May 11 to July 23 class period
June 1 — Belgian AML investigation reported — More than €500M in suspicious transactions reported; shares fell as much as 19% intraday
July 21 — OCC denies proposed Wise National Trust charter — OCC cites supervisory, AML/CFT, management and fiduciary-experience concerns
July 24 — Wise announces planned GENIUS Act framework reapplication — Original master-account-dependent structure called non-viable
July 31 — Daugherty v. Wise Group plc filed in SDNY — New securities-litigation exposure for Wise and named executives
September 29 — Lead-plaintiff motion deadline — Deadline for eligible investors seeking to direct the putative class
OCC Rejection Was More Than a Payments-Rail Delay
The Office of the Comptroller of the Currency formally denied the application to charter Wise National Trust in Austin, Texas, on July 21. The proposed bank would have offered stored-value multi-currency accounts, payment processing and fiduciary services, and Wise expected a potential Federal Reserve master account to make its U.S. operation more efficient as it scaled.[2]
The agency's reasoning went beyond the economics of direct settlement. It concluded that the application presented “significant supervisory and compliance concerns” and did not demonstrate that the proposed bank would operate in compliance with applicable law. The decision cited the July 2025 multistate consent order, which identified deficiencies in suspicious-activity investigation and reporting, transaction-monitoring data integrity, timely suspicious-activity reports and independent review. That order included a $4.2 million administrative penalty.[2]
The OCC further found that the organisers had not shown sufficient familiarity with national-banking law, that the proposed management and board lacked adequate relevant competence, and that the group had not demonstrated enough experience in national-bank fiduciary activities. Its conclusion was unusually direct: the proposed leadership had shown a “persistent inability” to manage the money-laundering, terrorist-financing and illicit-finance risks associated with the planned activities.[2]
Wise rejects the idea that the decision alters its operating footing. It says it has strengthened U.S. investigations, reporting, customer-data integrity and compliance resources since the consent order; its existing money-transmitter licences span 48 states and four territories, alongside more than 80 licences globally.[3]
“With the Federal Reserve generally pausing account access for an uninsured trust bank, the approach in our application became non-viable.”
Wise, July 24, 2026[3]
The GENIUS Refile Changes the Lane, Not the Burden of Proof
Wise says it will submit a new national trust-bank application under a GENIUS Act framework. That law created a federal framework for payment stablecoins, and an application aligned to it creates a possible route for Wise to become a permitted payment-stablecoin issuer or to build stablecoin functionality around its payments network. It does not, on its own, establish that Wise will issue a token, nor does it erase the AML/CFT issues identified by the OCC.[2][3]
The strategic pivot follows the Federal Reserve's May payment-account proposal, widely described as a skinny-master-account framework. The proposal would create a limited, prefunded payment account rather than a full master account, with no interest, discount-window access or intraday credit. Crucially for Wise's original plan, the Board encouraged Reserve Banks to pause decisions on Tier 3 access requests while the framework is developed, with the proposed pause expected to run no later than December 31, 2026.[4]
William Blair analysts Cristopher Kennedy and Marc Feldman wrote that the reapplication was not a meaningful change in Wise's stablecoin strategy. Their read is that Wise remains focused on reducing cross-border transaction costs and is agnostic about the rail, even though the regulatory wrapper now puts stablecoin issuance more visibly in the strategic conversation.[6]
The contrast with other fintech expansion stories is sharp. Australia’s prudential regulator granted Revolut Payments Australia an authorised deposit-taking institution licence on July 21, while the OCC gave Nubank preliminary conditional approval for a U.S. national-bank charter in January, subject to pre-opening requirements including FDIC insurance and Federal Reserve stock. Wise, by contrast, must show that its revised model and control environment answer the specific concerns in Corporate Decision #1381 before it can turn a new filing into a comparable regulatory advance.[7][8]
A Compressed Window for Credibility
None of these developments by itself halts Wise's existing U.S. business. The company continues to operate under its money-transmitter licences, the OCC denial permits a de novo application, and the securities case remains at the allegation stage. But their interaction matters. The Belgian investigation challenges the robustness of the group's controls, the OCC ruling sets out a demanding official assessment of U.S. compliance and governance, and the class action seeks to convert the disclosure sequence into investor damages.
For Wise, the next application is therefore not simply a reroute from a trust charter to a stablecoin framework. It is a test of whether a new legal structure, with a different Federal Reserve access backdrop, can persuade regulators that the enterprise-wide control weaknesses identified in the prior decision have been remediated. With a September 29 lead-plaintiff deadline, the company must navigate that regulatory reset while the market receives a fuller legal account of the summer's disclosures.
References
[1] Holzer & Holzer LLC, “Daugherty v. Wise Group plc, et al., Class Action Complaint,” July 31, 2026. https://holzerlaw.com/wp-content/uploads/2026/08/Complaint_Filed.pdf
[2] Office of the Comptroller of the Currency, “Corporate Decision #1381,” July 21, 2026. https://www.occ.gov/topics/charters-and-licensing/interpretations-and-decisions/2026/cd1381.pdf
[3] Wise Group plc, “Wise US national trust bank charter application,” July 24, 2026. https://owners.wise.com/news-releases/news-release-details/wise-us-national-trust-bank-charter-application
[4] Board of Governors of the Federal Reserve System, “Request for Comment on Proposed Establishment of a Payment Account,” May 2026. https://www.federalreserve.gov/newsevents/pressreleases/files/other20260520a1.pdf
[5] Reuters, “Fintech Wise's shares fall after report of Belgian prosecutor investigation,” June 1, 2026. https://www.reuters.com/legal/government/fintech-wises-shares-fall-after-report-belgian-prosecutor-investigation-2026-06-01/
[6] The Block, “Wise plans to resubmit national trust bank application under GENIUS Act framework,” July 24, 2026. https://www.theblock.co/post/409631/wise-plans-resubmit-national-trust-bank-application-under-genius-act-framework
[7] Australian Prudential Regulation Authority, “APRA grants ADI licence to Revolut,” July 21, 2026. https://www.apra.gov.au/news-and-publications/apra-grants-adi-licence-revolut
[8] Office of the Comptroller of the Currency, “Conditional Approval #1362: Application to Charter Nubank, National Association,” January 29, 2026. https://www.occ.gov/topics/charters-and-licensing/interpretations-and-decisions/2026/ca1362.pdf