Cross-border payments company Wise plans to resubmit its application to the US Office of the Comptroller of the Currency (OCC) for a national trust bank charter, this time under the GENIUS Act framework. According to The Block’s report, the OCC has issued conditional approvals to several stablecoin-focused applicants since last December. The GENIUS Act is the first US federal law specifically regulating payment stablecoins — the full bill text is available on congress.gov’s S.1582 page. Its core move is to consolidate the fragmented state-by-state rules on “who can issue dollar stablecoins, what reserve assets are required, and who supervises them” into a federal-plus-state dual-track licensing regime. Wise itself is not a crypto company — what it wants is reserve custody rights and direct access to the US payment system. That it chose to refile under the GENIUS Act framework shows this charter has now become the standard entry point for dollar digitized payments, rather than a niche channel for crypto companies.
Editorial take: what this means for the card in your hand
Whether Wise gets its charter has no direct bearing on whether you can pay for ChatGPT Plus this month. But the direction it reveals is directly relevant: the clearing layer for dollar stablecoins is being folded into bank regulation, and USDT is not on the core beneficiary list of this framework.
The most directly affected are cards with US BINs. As the upstream banks, reserve custodians, and clearing partners behind card issuers come one by one under OCC oversight, their preferences for funding currencies will tilt more clearly toward regulated dollar tokens. This is also why the US Direct variant of MPCard is currently suspended from issuance, while the Asia-Pacific Asia Elite line remains the most stable option — the combination of an Asia-Pacific account, Asia-Pacific IP, and Asia-Pacific card BIN doesn’t run through the compliance review pressure points of the US banking system. By the same logic, products like Coinbase Card, which already operate within the US licensed system, benefit from clearer rules; whereas aggregator-style products that rely mainly on USDT for funding will depend on the structure of their respective upstream channels.
Timeline expectations: within 7 days, there will be no user-perceptible changes — don’t touch your balance because of this news. Within 30 days, worth watching is whether the OCC formally lists Wise’s application status in its weekly licensing bulletin. Within 90 days, if you use a card with a US-BIN variant, watch for whether the issuer adjusts supported funding currencies or raises verification requirements for US-region subscription transactions. Readers weighing their options in this window can cross-reference the 2026 USDT Virtual Card Top 5 for each card’s channel affiliation.
Historical comparisons: three similar, one different
The first comparison is 2021. Anchorage obtained an OCC national trust bank charter, and Paxos and Protego received conditional approvals — at the time, the market similarly read this as “crypto entering the banking system,” but the subsequent rollout for both didn’t go smoothly, with a substantial gap between conditional approval and actually opening for business. What’s the same this time: conditional approval is still just conditional. What’s different: in 2021 there was no dedicated legislation, and OCC’s interpretive letters shifted repeatedly with changes in leadership. Now there’s the GENIUS Act as codified law underpinning it — the rules won’t be overturned wholesale by a single personnel change.
The second comparison is the USDC de-peg in March 2023. The Silicon Valley Bank collapse briefly sent USDC down to around $0.87, exposing the fact that reserve banking doesn’t equal reserve safety. The GENIUS Act’s requirements on reserve asset categories and disclosure frequency are essentially patching this hole — for cardholders, this means the extreme tail risk of regulated stablecoins is decreasing, but at the cost of a higher barrier to entry.
The third comparison is MiCAR’s stablecoin provisions taking effect on June 30, 2024. In the EU, the result at the time was that some exchanges delisted or restricted USDT trading pairs. A similarly severe retail-side disruption is unlikely in the US this time — the GENIUS Act governs the issuance side, not the holding side — but the stratification of “compliant dollar tokens on the main rails, USDT on aggregator rails” will become more pronounced. EU residents can refer to the EU Compliance Guide for their specific situation.
Compliance boundaries: what’s allowed and what isn’t, right now
For individual cardholders, the boundaries currently look like this: clearly permitted — holding and transferring USDT within the United States is not illegal, and using a virtual card to pay for legal goods and services is likewise not illegal. Gray area — non-US-licensed entities providing card issuance and stablecoin funding services to US users fall into an area where enforcement intensity depends on subsequent implementing rules and state-level attitudes. Clearly restricted — issuance and promotion within the United States of payment stablecoins that don’t meet GENIUS Act requirements will face tighter scrutiny. For details and updates, refer to the US Compliance Guide.
One reminder: this framework governs issuers and banks, not you personally. If you see claims like “USDT is going to be banned in the US,” check the bill’s applicability clauses first.
Four checkpoints worth watching next
- OCC Weekly Bulletin: whether Wise’s application is formally listed as received — this is the only verifiable signal marking the shift from “planning to submit” to “in process.”
- Progress of already-conditionally-approved entities toward opening: conditional approval converting into actual operation is the step the 2021 script never completed.
- Public comment period for GENIUS Act implementing rules: the final wording on reserve asset scope and disclosure frequency will determine how large the gap is between USDT and compliant dollar tokens.
- Issuer announcements on funding currencies: especially for products with US-BIN variants — any announcement of “suspending support for funding in a certain currency” is more actionable than the news itself.
Editorial recommendations
Users on Asia-Pacific rail virtual cards need take no action. The channel structure behind the MPCard Asia Elite review doesn’t pass through this round’s compliance review pressure points within the US banking system. Fees and limits remain as stated on the official page, and this news is not grounds for any adjustment.
Users relying on US-BIN cards for AI tool subscriptions are advised not to let more than two or three months’ worth of subscription funds accumulate on a single US-region card — small recurring charges like ChatGPT Plus at $20/month or Claude Pro at $20/month are naturally suited to small, frequent top-ups anyway. For specific setups, see the ChatGPT Plus payment scenario.
Users planning to apply for a new US-region variant card should hold off for 30 days, waiting for the OCC bulletin and issuer currency policies to settle before deciding. If your core need is simply low fees for running subscriptions, go straight to the Lowest-Fee USDT Card Comparison — there’s no need to wait out this round of regulatory dust-settling.
What’s not recommended: swapping your USDT for other stablecoins because of this news. The GENIUS Act’s scope applies to issuers — the usability of the ₮ you’re holding won’t change within 90 days because of a charter application.