Wise’s US Charter Rejection Exposes the Gap Between Stablecoin Policy and Fed Access

Wise plans to reapply for a US national trust bank charter under the GENIUS Act framework after regulators rejected its original bid, but analysts at William Blair do not expect the cross-border payments company to make a major strategic turn toward stablecoins.

The Office of the Comptroller of the Currency denied Wise’s initial application in a July 21 letter, citing a conflict between the company’s proposed operating model and emerging Federal Reserve policies governing direct access to US payment systems.

Wise is now preparing a revised application structured around the GENIUS Act, the federal stablecoin law passed in the summer of 2025. The legislation established a regulatory framework for payment stablecoins backed by high-quality liquid reserves such as cash and US Treasuries.

The reapplication would give Wise another route into the federally regulated payments system, though William Blair analysts Cristopher Kennedy and Marc Feldman said the move should not be interpreted as a fundamental change in the company’s views on digital assets.

“Although Wise plans to submit a new application under a Genius Act framework, we do not anticipate a major shift in the company’s stance on stablecoins — Wise is focused on lowering the cost of cross-border transactions, agnostic of the rail,” the analysts wrote.

Wise has consistently presented itself as a payments infrastructure provider rather than a crypto company. Its core business centers on reducing the cost and complexity of moving money across borders through a network that connects domestic payment systems.

The company has said its technology can interoperate with both blockchain-based infrastructure and traditional banking rails. That flexibility could allow Wise to use stablecoins where they improve settlement efficiency without turning stablecoin issuance into the center of its business model.

Fed Access Complicates Wise’s Original Plan

Wise’s first charter application reportedly relied on the company obtaining a Federal Reserve Master Account, which would have allowed it to connect more directly to US payment systems.

Master Accounts provide eligible financial institutions with access to Federal Reserve services, including Fedwire. Direct access can reduce reliance on intermediary banks and give payment companies more control over settlement, liquidity and transaction costs.

The OCC said Wise’s proposal was no longer compatible with the Federal Reserve’s latest direction on Master Account access.

According to William Blair, the Fed has effectively slowed or halted the granting of new Master Accounts while it develops a separate framework for limited-purpose “payment accounts.”

The Federal Reserve formally proposed that payment-account framework in May 2026. The proposal included restrictions affecting Tier 3 applicants, which generally include uninsured institutions that are not federally supervised.

Wise’s original structure depended on access that regulators were no longer prepared to grant under the previous process.

“While approval would have represented a step towards a connection to US domestic rails, we understand the Fed has essentially halted the granting of master accounts, as it develops policies for ‘payment accounts’ that were formally proposed in May 2026,” Kennedy and Feldman said.

That leaves Wise with a regulatory problem that goes beyond the OCC.

A national trust charter can provide federal supervision and a clearer legal structure, but it does not automatically guarantee access to Federal Reserve payment infrastructure. The Fed retains separate authority over Master Accounts and related services.

The rejection therefore highlights the fragmented nature of US payments regulation. A firm may satisfy one regulator’s requirements and still face a barrier at another agency controlling the infrastructure it needs.

OCC Opens Door to Crypto and Stablecoin Firms

Wise’s setback comes as the OCC has taken a more welcoming approach toward digital asset firms under President Donald Trump’s second administration.

Since December, the OCC has granted conditional approval to several companies seeking national trust bank charters connected to stablecoin custody, issuance or digital asset services.

Entities affiliated with BitGo, Circle, Fidelity, Paxos and Ripple received conditional approvals. BitGo was also granted full approval to convert its existing state trust company into a federally regulated entity.

Other applicants, including Crypto.com, Coinbase and Nomura-backed Laser Digital National Trust Bank, later received conditional approval. Sony Bank subsidiary Connectia was approved, while Upstart received conditional approval for a national bank focused mainly on artificial intelligence rather than crypto.

Traditional financial companies have also started exploring charter applications as interest in regulated stablecoin infrastructure spreads beyond the crypto industry.

Morgan Stanley and Charles Schwab are among the firms that have begun OCC application processes as banks, brokerages and payment companies assess how stablecoins could be used in settlement, trading and customer payments.

Circle secured official charter status earlier this month, joining BitGo and Anchorage Digital among the small group of crypto-linked companies holding national trust charters.

Anchorage Digital had been the only crypto company with a federal trust charter for several years after receiving approval in 2021.

The increase in applications shows how quickly the regulatory environment has changed since the GENIUS Act became law.

Before the legislation, companies had to work through a patchwork of state money-transmission laws, banking rules and informal guidance. The GENIUS Act created a clearer legal category for payment stablecoins and set reserve, custody and supervisory requirements.

The law did not remove every obstacle.

Companies still need regulatory approval, suitable compliance systems and workable access to banking and settlement infrastructure. Wise’s rejection shows that federal charters and payment-system access remain separate questions.

Compliance History Also Drew Scrutiny

The OCC’s denial reportedly referred to Wise’s historical compliance record, including a July 2025 multi-state consent order related to deficiencies in anti-money laundering risk management.

Wise has said it strengthened its controls following the order.

Compliance issues are especially important in cross-border payments because companies must monitor transactions across multiple jurisdictions, customer types and banking systems.

A national charter applicant is expected to show that its anti-money laundering program, sanctions controls, governance and risk management are strong enough for federal supervision.

Wise’s revised application may need to demonstrate not only that its technology fits within the GENIUS Act but also that the company has addressed the specific weaknesses cited by regulators.

The company’s ability to secure approval could depend as much on its compliance remediation as on its stablecoin strategy.

Kraken Shows That Limited Fed Access Is Possible

The Federal Reserve Bank of Kansas City approved a limited-purpose Master Account for Wyoming-chartered Kraken Financial in March, giving the crypto bank direct access to services such as Fedwire.

Kraken Financial became the first crypto firm to secure that type of access.

The approval suggested that the Federal Reserve was not completely closing the door to digital asset institutions, but the limited structure also showed that access may be tightly controlled.

Kraken’s model may not be directly available to Wise, particularly if the Fed continues moving toward a new payment-account regime with narrower permissions and more specific eligibility rules.

The distinction matters because payment companies do not necessarily need the full range of services available to a traditional bank.

A limited payment account could support settlement while restricting activities such as borrowing from the Fed or earning interest on balances.

That type of arrangement may eventually offer Wise a viable route to domestic US rails, but the final rules have not yet been settled.

Stablecoins Remain a Tool, Not the Strategy

William Blair’s central argument is that Wise will remain focused on the cost of moving money rather than on the technology used for settlement.

Stablecoins could help Wise reduce settlement time or improve liquidity in certain corridors. They could also provide an alternative when traditional correspondent banking is expensive or slow.

But Wise already operates through a network that minimizes the need for money to cross borders in the conventional sense. The company collects funds locally and pays recipients through domestic systems whenever possible.

That model has helped Wise reduce costs without depending on blockchain infrastructure.

Stablecoins could be added where useful, but they do not automatically replace Wise’s existing network.

The company’s position is therefore less ideological than practical.

If blockchain rails are cheaper, Wise can use them.

If domestic banking rails are more efficient, it can stay with those.

William Blair reiterated its Outperform rating on Wise and said its discounted cash flow analysis supports a stock price of at least $19.

The analysts appear to view the charter rejection as a regulatory delay rather than a challenge to Wise’s broader business model.

Wise’s Charter Problem Is Not Really About Stablecoins

Here is the part that keeps getting blurred.

Wise is not suddenly trying to become Circle.

The company is not waking up one morning, staring at the stablecoin market and deciding it needs a token. That is not what this looks like.

The new GENIUS Act application is a regulatory workaround.

Maybe a smart one.

Wise wanted a cleaner connection to US domestic payment rails. Its original charter plan leaned on getting a Fed Master Account. Then the Fed changed the mood, slowed the process and started building a new category of limited payment accounts.

That broke the original setup.

So Wise is adjusting.

Not pivoting.

There is a big difference.

The Charter Was Never the Prize

The charter sounds important because “national trust bank” carries weight. Federal supervision. Regulatory legitimacy. A cleaner structure.

But the real prize was access.

Fedwire. Domestic settlement. Less dependence on banking partners. Better control over how money moves inside the US.

That is where the economics get interesting.

Every intermediary adds cost, delay and operational risk. Wise built its entire business by stripping those layers out of cross-border transfers.

A direct connection to US rails fits that model perfectly.

The charter was a means to get closer to the pipes.

Then the Fed effectively said the pipe was not available under the structure Wise expected.

That is why the OCC rejection matters.

The OCC did not just say Wise filed the wrong paperwork. It said the operating model did not line up with how the Fed now wants payment access to work.

That puts Wise in an awkward spot.

One regulator can approve the entity.

Another controls the thing the entity actually needs.

Welcome to US financial regulation.

The GENIUS Act Is Becoming the New Door

This is where the stablecoin angle gets misunderstood.

The GENIUS Act created a cleaner federal lane for payment stablecoin companies. That lane is now attracting everyone.

Crypto firms.

Banks.

Brokerages.

Payment companies.

Firms that barely talked about stablecoins 18 months ago are now filing applications because the legal route exists.

That does not mean all of them want to issue a dollar token.

Some want custody.

Some want settlement access.

Some want optionality.

Some simply do not want competitors to get there first.

Wise likely sits in the optionality camp.

A GENIUS Act charter could let the company build infrastructure that works with stablecoins without betting the business on them.

That is the sensible move.

I would be more worried if Wise suddenly started talking like a crypto startup. Tokenized money. Borderless finance. Programmable value. All the usual deck language.

It is not.

Wise still sounds obsessed with one thing: lower transaction costs.

That discipline matters.

Stablecoins Do Not Automatically Beat Wise’s Existing Model

Crypto people often talk about stablecoins as if cross-border payments are already solved.

Send USDC.

Done.

Except it is not that simple.

The sender needs access.

The recipient needs liquidity.

The off-ramp needs to work.

Compliance still exists.

FX still exists.

Local banking still exists.

Somebody still has to turn the token into usable money.

Wise already solved a chunk of that through local accounts and domestic payout networks.

A customer sends money in one country. Wise pays the recipient from funds already sitting in another country. The money does not always cross the border in the way the customer imagines.

It is a balance-sheet and liquidity-routing game.

Stablecoins can improve pieces of that.

They can speed up internal settlement between entities. They can help move liquidity outside banking hours. They can reduce friction in corridors where correspondent banking is weak.

But they are not magic.

If the recipient wants dollars in a bank account, Wise still needs a bank connection somewhere.

If the merchant does not accept stablecoins, somebody still needs to convert.

That is why Wise being “agnostic of the rail” is not empty corporate language. It is probably the correct strategy.

Use whatever rail is cheapest.

That is the product.

The Fed Is the Real Bottleneck

The OCC has been approving crypto-related charters at a pace that would have looked impossible a few years ago.

Circle. BitGo. Ripple-related entities. Paxos. Fidelity. Coinbase. Crypto.com. The list keeps growing.

That creates the impression that federal regulators have fully opened the gates.

They have not.

The OCC can approve charters.

The Fed still controls access to the core payment system.

That split is now the biggest structural issue in this story.

A trust bank charter without meaningful Fed access can still be useful. It can support custody, supervision and certain stablecoin activities.

But it does not give Wise the direct connection it originally wanted.

And if the Fed’s future payment-account framework offers limited access only, Wise may end up with something narrower than a traditional Master Account.

Still useful.

Just not the full package.

I think that is where this is heading.

The Fed does not want every fintech, stablecoin issuer and uninsured trust company sitting inside the payment system with bank-like privileges.

So it will create a fenced-off account.

Payments allowed.

Credit access limited.

Balances controlled.

No assumption that the company is a normal commercial bank.

That is probably the compromise.

Kraken Is the Exception Everyone Will Point To

Kraken Financial getting a limited-purpose Master Account was a big deal.

It proved crypto firms are not permanently locked out.

But I would not treat it as a template Wise can copy tomorrow.

Kraken spent years fighting for access. It operates under a Wyoming special-purpose charter. Its account is limited. The approval came through the Kansas City Fed, and the details matter.

Wise is a different company with a different model and a different regulatory history.

The Fed can approve one limited case without opening the floodgates.

Still, Kraken’s approval gives Wise something to point at.

The argument becomes simple: limited direct access already exists for a crypto-linked institution, so why not build a controlled framework for payment firms that meet federal standards?

That debate is coming.

The Compliance Issue Is More Dangerous Than the Stablecoin Issue

This part deserves more attention.

Wise’s 2025 anti-money laundering consent order could matter more than the entire stablecoin debate.

Regulators can tolerate strategic ambiguity. They do not tolerate weak controls.

Cross-border payments are a high-risk business. Money moves across jurisdictions, customer types and financial systems. Bad actors love speed and fragmented oversight.

Wise says it improved its systems after the consent order.

It will need to prove that.

A revised application will not get through on product logic alone. The company has to show that its monitoring, governance, sanctions controls and risk management are ready for federal supervision.

That is the real test.

A shiny GENIUS Act framework will not cover a weak compliance file.

The OCC’s Crypto Shift Is Real, but It Is Not Charity

The OCC is clearly more receptive to digital asset firms than it was under the previous administration.

That is obvious.

But approvals are not favors.

The regulator is building a supervised lane because stablecoins are too large to leave in the gray zone. Better to bring issuers and infrastructure firms inside a chartered framework than let them operate through fragmented state licenses forever.

There is also a competitive angle.

The US does not want regulated stablecoin activity moving offshore while dollar-based tokens keep growing globally.

So the OCC is moving fast.

Wise can benefit from that opening even if it is not a stablecoin company in the usual sense.

That is the smart part of the reapplication.

The company does not need to love stablecoins.

It just needs the framework to solve a payments problem.

William Blair Is Probably Right

I agree with the analysts.

This does not look like a major change in Wise’s strategy.

It looks like infrastructure shopping.

Wise will use blockchain rails when they save money. It will use bank rails when they work better. It will keep pushing for direct access because every extra bank in the chain eats margin.

That is the whole game.

The market may still overreact to the charter language because stablecoin applications now come with a valuation narrative. Investors hear GENIUS Act and start pricing in token issuance, custody revenue and blockchain expansion.

Maybe some of that happens.

But I would not build the thesis around it.

Wise’s edge is not that it can issue a stablecoin.

Its edge is that it can route money efficiently across a messy global network.

Stablecoins are another pipe.

Nothing more.

What I’d Watch Next

First, the exact structure of the new application.

Does Wise seek authority to issue a payment stablecoin, hold reserves, provide custody or simply operate under a framework that improves settlement access?

Those are very different businesses.

Second, the Fed’s final payment-account rules.

That decision matters more than the OCC headline. If the Fed creates a workable limited account for federally supervised payment firms, Wise may finally get the access it wanted through a different door.

Third, compliance.

Any fresh criticism around anti-money laundering controls could slow the application regardless of how crypto-friendly the environment becomes.

And last, whether Wise actually puts stablecoins into production.

Not pilot language.

Not interoperability claims.

Real transaction volume.

My guess?

Wise will use stablecoins quietly in the background before it ever markets them as a major customer product.

That would fit the company.

No token hype. No crypto costume.

Just another rail, plugged into the machine, doing the job if it is cheaper.