In a surprising twist, the Office of the Comptroller of the Currency (OCC) denied an application for a national trust bank charter submitted by proposed Wise National Trust, a subsidiary of Wise plc, a global payments company headquartered in the United Kingdom. (Wise),1 based on myriad concerns related to Wise’s anti-money laundering compliance and management.2 Notably, many of these concerns came to light shortly after Wise submitted its application to the OCC, when Wise US became a party to a multistate consent order addressing deficiencies in its Bank Secrecy Act, Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) program.3