The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued an Advisory urging financial institutions to be vigilant against risks presented by the unlawful employment of illegal aliens, aiming to secure the U.S. financial system.
Issued on June 5, 2026, the advisory was developed jointly with the Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, and National Credit Union Administration, and in coordination with the Internal Revenue Service. It supports Executive Order 14406, "Restoring Integrity to America’s Financial System." Secretary of the Treasury Scott Bessent said, “President Trump has done more than anyone in history to secure our nation’s borders. Part of that effort includes securing our financial system. This Administration will not allow illegal aliens to abuse financial institutions to steal billions of dollars from hardworking American taxpayers.”
Employers who hire, conceal, and exploit non-work authorized populations can gain an unfair advantage, depress wages, facilitate identity theft, and steal tax revenue. Schemes to pay unlawful workers often rely on the U.S. financial system and can facilitate the financing of transnational criminal organizations involved in drug and human trafficking. In 2025, financial institutions reported over $2.5 billion in suspicious activity linked to payroll tax fraud schemes, which often involve complicit labor brokers using shell companies and foreign identity documents or Individual Taxpayer Identification Numbers (ITINs) to launder funds and pay workers without withholding taxes.
FinCEN encourages banks to consider the use of an ITIN as a relevant risk factor when applying customer due diligence, especially when it is presented in lieu of a Social Security number or valid employment authorization. The advisory includes 18 red flag indicators to help financial institutions detect and report suspicious activity, requesting the key term “FINANCIALINTEGRITY-2026-A002” be used in Suspicious Activity Reports (SARs). Tips about employers knowingly employing unauthorized workers can also be reported to Immigration and Customs Enforcement.