The Consumer Financial Protection Bureau (CFPB) issued an Amended Consent Order against Wise US on May 16, significantly revising a previously reported multi-million-dollar enforcement action.
The updated order reduced the civil penalty from over $2 million to just $44,955, while preserving approximately $449,550 in consumer redress.
The original fine, issued in January 2025, centered on violations of the Electronic Fund Transfer Act (EFTA) and Consumer Financial Protection Act (CFPA).
The CFPB alleged that Wise had misled US consumers regarding ATM withdrawal fees and failed to adhere to required disclosure and error-resolution standards for both prepaid accounts and remittance transfers.
Among the issues highlighted:
- Misleading blog posts about ATM fees that overcharged thousands of U.S. users by roughly $156,000.
- Inaccurate or missing disclosures for fees on balances above €15,000 and funding via Apple Pay or Google Pay using credit cards.
- Failure to issue timely notices of error, refunds, and proper foreign language disclosures, violating several provisions of Regulation E.
Despite the scope of the findings, the CFPB’s final enforcement decision marks a substantial scaling back of the original penalty.
Regulatory shifts and internal reforms
The reduction appears to reflect both a change in CFPB leadership and a policy recalibration. Acting Director Russell Vought, who assumed office following the departure of Rohit Chopra, has overseen a more restrained enforcement posture. I
In parallel, the CFPB has rescinded certain guidance, including Consumer Financial Protection Circular 2024-02, which may have narrowed the interpretation of liability in digital payments compliance.
In addition, the Bureau acknowledged that Wise cooperated fully, proactively remedied violations, and had already refunded a substantial portion of affected consumers by November 2022. These mitigating factors likely weighed heavily in the agency’s revised enforcement calculus.
Implications for the cross-border payments sector
There is growing regulatory complexity for remittance providers and digital wallet platforms, particularly those operating at scale.
Wise, a subsidiary of London-listed Wise plc, serves over 3 million US customers and generated approximately $157.3m in revenue from US remittance and prepaid services between April 2022 and March 2023.
For payment firms, Wise’s latest dabble with the law has two core takeaways. Firstly, the CFPB found that Wise’s violations stemmed in part from failing to adequately expand its compliance infrastructure as its US footprint grew. Secondly, even well-intentioned fintechs risk regulatory exposure if they do not adhere to strict consumer disclosure and dispute resolution standards.
Next steps for Wise
Under the terms of the consent order, Wise must:
- Submit a detailed Compliance Plan within 60 days.
- Implement board-level oversight and annual staff training on US financial regulations.
- Report back to the CFPB on progress and maintain rigorous documentation protocols for at least five years.
While the civil penalty is now relatively minor, the reputational cost and compliance obligations serve as a reminder of the importance of rigorous internal controls in consumer financial services.
