An advisory issued jointly Friday by bank and credit union prudential regulators with Treasury’s financial crimes enforcement arm encourages the institutions to aid in the detection and reporting of illegal aliens.
The agencies – Treasury’s Financial Crimes Enforcement Network (FinCEN), Federal Deposit Insurance Corp. (FDIC), National Credit Union Administration (NCUA) and Office of the Comptroller of the Currency (OCC) – issued the advisory in coordination with the Internal Revenue Service (IRS). It advises financial institutions – banks, credit unions and savings institutions – “to be vigilant against fraud schemes and other suspicious or potentially criminal activities involving the unlawful employment of illegal aliens and the associated risks to the integrity of the U.S. financial system.”
The advisory follows an executive order issued by President Donald Trump in May focusing on individuals not authorized to work in the U.S. gaining access to the nation’s financial system.
Treasury, in a release, summarized that the advisory encourages financial institutions to consider the use of an ITIN (Individual Taxpayer Identification Number) when applying appropriate risk-based procedures for customer due diligence under Bank Secrecy Act (BSA) rules “in light of the totality of other factors and available information.” It said when an ITIN is presented in lieu of a Social Security number (SSN) or valid employment authorization document to obtain credit products or open an account, institutions are encouraged to assess whether the use of an ITIN may be a relevant risk factor.
Where the institution has “risk-based” concerns about the SSN presented by a customer, the advisory says FinCEN “encourages financial institutions to verify the SSN to determine if it matches the Social Security Administration’s (SSA) records”
Included in the advisory are 18 red flag indicators to help financial institutions detect, prevent, and report suspicious activity connected to fraud schemes involving the unlawful employment of unlawful aliens, it said.
FinCEN, in the advisory, requested that financial institutions use the key term “FINANCIALINTEGRITY-2026-A002” in suspicious activity report (SAR) field 2 (Filing Institution Note to FinCEN) and the narrative to indicate a connection between the suspicious activity being reported and the activities highlighted in this Advisory.
“In addition to filing a Suspicious Activity Report, FinCEN encourages financial institutions and the public to report any tips or complaints about employers that knowingly employ and/or exploit unauthorized workers to Immigration and Customs Enforcement’s Tip Form or by phone (number in the release).
FinCEN advisory: FIN-2026-A002
Treasury release: FinCEN Asks Financial Institutions to Detect and Report Illicit Activity Related to Illegal Aliens
NCUA release: Federal Prudential Regulators Ask Financial Institutions to Detect and Report Illicit Activity Related to Illegal Aliens
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