The New York Department of Financial Services and a coalition of state money-transmission regulators signed 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. The action represents one of the most significant regulatory interventions against a major international money transfer operator in the United States in recent years.
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, which encompasses the policies, procedures, systems, and controls that a financial institution maintains to detect and prevent its services from being used to launder money. Regulators found that Wise US's AML programme was deficient in material respects, meaning that the firm's ability to identify and respond to financial crime risk was compromised.
The second category concerns the timeliness of Suspicious Activity Report filings. Under the Bank Secrecy Act, financial institutions are required to file SARs within 30 days of detecting a suspicious transaction, or within 60 days if additional time is needed to identify a subject. Delayed filings undermine the ability of law enforcement agencies to act on intelligence in a timely manner, particularly in cases involving fast-moving transactions that may cross multiple institutions and jurisdictions.
The third category covers broader BSA compliance deficiencies, which include obligations around customer identification, recordkeeping, and the overall integrity of the compliance management system. For a money transfer operator handling cross-border transactions at the scale of Wise US, these obligations carry particular weight given the elevated inherent risk of international funds transfers being used to move illicit proceeds across borders.
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 submit to periodic independent audits, the results of which will be reported to the regulators. These requirements are designed to provide assurance that the identified deficiencies are remediated in a sustainable and verifiable manner rather than through superficial policy changes.
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. Coordinating enforcement across multiple state regulators, led by NYDFS, ensures that the consent order carries binding effect across Wise US's full operating footprint.
For Wise plc and its US operations, the consent order comes at a time when the company has been expanding its product range and customer base in the American market. The $4.2 million penalty and the associated compliance obligations will require sustained management attention and investment in the compliance function. The action also serves as a signal to the broader international payments sector that US regulators expect money-transmission licensees to maintain AML and BSA controls commensurate with the volume and risk profile of their transaction activity.