Six US State Regulators Issue $4.2 Million Consent Order Against Wise US for AML and BSA Failures

Money-transmission regulators in six US states, California, Massachusetts, Minnesota, Nebraska, New York and Texas, announced a multistate consent order on 9 July 2025 imposing a $4.2 million penalty on Wise US Inc., the American subsidiary of Wise plc, for failures in its anti-money laundering programme, delayed Suspicious Activity Report filings, and non-compliance with the Bank Secrecy Act.

Wise US Inc. operates as a licensed money transmitter across US states, providing the domestic regulatory foundation for the international payments and money transfer services offered by its parent, Wise plc, which is listed in London and was formerly known as TransferWise. The consent order applies specifically to the US subsidiary's obligations under federal and state money-transmission licensing requirements.

AML FAILURES AND DELAYED SUSPICIOUS ACTIVITY REPORTS

The core violations identified in the consent order fall into three categories. The first is failures in the anti-money laundering programme itself. Regulators found that Wise US's AML programme was deficient in material respects.

The second category concerns the timeliness of Suspicious Activity Report filings. Under FinCEN's rules for money services businesses such as Wise US, a SAR must be filed within 30 calendar days of initial detection of the suspicious activity.

The examination also cited failure to provide for an independent review of the AML programme at an appropriate frequency, transaction-monitoring data integrity issues, failure to correct past deficiencies in a timely manner, and violations of the CFPB's Remittance Transfer Rule.

ENHANCED CONTROLS AND INDEPENDENT AUDITS REQUIRED

As part of the consent order, Wise US Inc. is required to implement an enhanced compliance programme and strengthen its BSA and AML controls. The firm must also retain an independent third party to verify its remediation and submit quarterly progress reports to the regulators for two years.

The multistate nature of the enforcement action reflects the structure of money-transmission licensing in the United States, where firms typically hold individual licences from each state in which they operate rather than a single federal licence. The six states acted jointly, following a multi-state examination covering July 2022 to September 2023.