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Est. Feb 2026 • Consumer Advocacy
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The Case
Legal AnalysisPrior Offender — CFPB Consent Order 2025-CFPB-0004
On January 30, 2025, the CFPB ordered Wise to pay $2.025 million in penalties and $450,000 in consumer redress for advertising inaccurate fees and failing to properly disclose exchange rates. However, the order was amended on May 15, 2025, reducing the civil penalty from $2.025M to just ~$45,000 — a 97.8% reduction. Wise stated it had already voluntarily paid the $450K to consumers before the order was even finalized. The conduct described in this case mirrors the same pattern: fees taken, service not delivered as promised.
Promissory Estoppel (Bait & Switch)
- 01Wise formally approved the account holder for card payments on Jan 27, 2026.
- 02Relying on this approval, a $1,037.50 transaction was processed on Feb 4.
- 03Wise revoked the feature on Feb 5 — AFTER capturing the funds.
- 04The website cited in the rejection was the SAME website on file during approval.
- 05You cannot retroactively apply a policy to seize funds processed under a valid approval.
The "Agent W-04" Admission — Misrepresentation
- 01On Feb 13 at 2:27 PM, Agent W-04 confirmed in writing: "the transfer will be refunded until the end of the day."
- 02Client was informed. Business decisions were made based on this official statement.
- 03Hours later, Agent W-05 retracted the promise and admitted Agent W-04 gave "false information."
- 04A company representative's written confirmation constitutes an actionable representation.
- 05Wise is liable for damages caused by reliance on their agent's false statement.
Unjust Enrichment — Fee Retention
- 01Wise is holding BOTH the principal ($1,037.50) AND the fee ($43.88).
- 02The service (card payment processing) was unilaterally cancelled by Wise.
- 03You cannot retain profit (fees) for a service you refuse to render.
- 04Wise publicly stated on Trustpilot: "in this case we aren't able to refund the fee."
- 05This is textbook unjust enrichment — profiting from a service they declined to perform.
Filed Complaints & Regulatory Actions
| Agency | Case ID | Description | Status |
|---|---|---|---|
| CFPB | #XXXXX-XXXX3622 | Money not available when promised | Rejected — Loophole |
| CFPB | #XXXXX-XXXX6805 | Material breach of Consent Order 2025-CFPB-0004 | Rejected — Loophole |
| NYDFS | Pending | Unsafe practices by licensed money transmitter | Filed |
| BBB | Pending | Deceptive business practices | Filed |
| FBI IC3 | Pending | Wire fraud — 18 U.S.C. § 1343 | Filed |
| OCC | Pending | Regulatory non-compliance | Filed |
| DE OSBC | Pending | Wise is incorporated in DE — banking regulator notified | Filed |
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