Wise on AML: 'It's difficult to get everything right'

• Key insight: Wise said it has addressed AML issues in a U.S. consent order. 
• Expert quote: "We've been investing in compliance in 'know your bank' and 'know your customer' over the past 15 years." —Wise Chief Financial Officer Emmanuel Thomassin

Wise contends it has addressed anti-money laundering concerns but does not have a timeline to resume its quest to receive a bank charter in the U.S.   

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 "We have provided the full remediation on every point that was part of the consent order," Emmanuel Thomassin, Wise's CFO, said during the company's earnings call Thursday night.  "We are now waiting for the feedback from the authorities."

The Office of the Comptroller of the Currency in July denied Wise's application to charter a de novo U.S. national trust bank, citing deficiencies in the company's Bank Secrecy Act, anti-money laundering and Countering the Financing of Terrorism program.  In mid-2025, Wise entered into a $4.2 million consent order with six U.S. state regulators over deficiencies in its AML program and suspicious-activity reporting. The Consumer Financial Protection Bureau (CFPB) cited Wise for deceptive marketing of ATM fees and remittance violations, resolving the action with an amended order requiring $450,000 in restitution and a civil penalty

This week, Thomassin said that while Wise waits for U.S. regulators to respond to the moves Wise has made to shore up its AML strategy, the timeline to resume its application for a charter is "open." "We've been investing in compliance in 'know your bank' and 'know your customer' over the past 15 years," Thomassin said. "We know our reputation depends on this."

Wise is not alone in facing government pressure over money laundering controls, as Bank of America this week was fined $1.2 billion over AML lapses.

"I can't comment on the other banks, what they are facing, but I think this is a reflection of how difficult it is to get everything right when you do AML," Thomassin said. 

Wise's earnings

For the quarter ending September 30, Wise reported net revenue of $739 million, up 21% over the the same quarter in 2025, with cross border volume growing 22% to $72 billion and customer holdings expanding 28% to $44 billion, Card spending was $14 billion in the quarter, up 30%. Wise raised its revenue growth to the upper half of a 15%-20% range. 

Wise recently moved its primary listing to the U.S., and has focused on expanding its outreach to small to medium sized businesses. Thomassin said the company has formed a dedicated team to engage with business owners.

 "We're reacting to the demand and questions that they may have, and also we also reach out to make sure that they can use in full the servicing that we offer," Thomassin said, adding the strategy differentiates Wise from legacy banks. "The second part of it is, we are getting more and more included in their internal workflow."

Wise is also attempting to compete with large business technology firms by offering an application programming interface that connects directly to small businesses, supporting other functions beyond financial services. "Small businesses may not opt for Oracle or SAP," Thomassin said. In other moves, Wise this quarter went live in Malaysia, launched the Wise Account and Wise Card in Thailand, introduced Wise Assets in New Zealand and announced Wise Platform partnership with OakNorth to support international payments for its U.K. business customers.

"We continued to expand our network, products and features so Wise can serve more people and businesses around the world," Kristo Käärmann, co-founder and chief executive officer of Wise, said in a statement.

'Margin pressure'

Analysts at William Blair noted Wise's commentary suggested broad-based strength across regions and the businesses, with North America being one of the fastest growing regions. 

"That said, the weakening dollar caused some moderation of high-value sends from the U.S. and currency fluctuations may drive continued volatility in reported growth rates," William Blair analysts said in a research note. "Revenue growth should moderate in the second half due to the timing of pricing/investments; however. We anticipate margin pressure in fiscal 2028 due to continued investment, yet we believe management will remain disciplined and view the opportunities from small businesses."

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Wise's approach is a self-reinforcing flywheel, William Blair analysts said. "More cross-border volume drives scale benefits and gross profit dollars, which are systematically reinvested in the product, technology, infrastructure, marketing, and price, all of which drive more volume."