According to the Consent Order:
• Multistate examination found AML deficiencies including (a) failure to provide for an independent review of the AML Program on a frequency commensurate with services provided; (b) deficiencies identified in processes for investigating and reporting suspicious activity, including the failure to timely file SARs; (c) transaction monitoring data integrity issues; (d) failure to timely correct past deficiencies detected in prior examinations and independent audits; and € violations related to the Consumer Financial Protection Bureau’s Remittance Transfer Rule.
• Notable “No admission” language: “Wise enters into this Order solely for the purpose of resolving disputes with the Participating Regulators concerning the conduct described in the Report of Examination and does not admit any wrongdoing, allegations or implications of fact and does not admit any violations of applicable laws, regulations or rules governing the conduct and operation of its money transmittal business, including related to its AML Program.”
• Remediation includes a 2-year lookback for certain transactions for SAR reporting purposes, and engagement of a third-party to conduct an independent review of the entirety of Wise’s AML program.