FinCEN Advisory on Non-Work Authorized Populations & ITIN Use

On June 5th, FinCEN issued a Joint Advisory on Non-Work Authorized Populations and Their Employers and Risks to the Integrity of the U.S. Financial System (FIN-2026-A002) directing financial 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.

One area of focus was the use of Individual Tax Identification Numbers (ITINs), and that when a person provides an ITIN to open an account or obtain a credit product instead of a social security number or valid work authorization documentation, financial institutions should consider whether this (in conjunction with other relevant information available) is a risk factor that would warrant enhanced customer due diligence procedures, such as ongoing monitoring and reporting.

In the video, Kevin outlines what this Advisory all covers.

BSA Training!

Published 2026/06/25

Kevin Edwards

Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).

Recent Posts

FinCEN Advisory on Non-Work Authorized Populations & ITIN Use

2026 FREE AML/CFT Compliance Q & A

Overdrafts & UDAAP Risk

FinCEN Advisory on Non-Work Authorized Populations & ITIN Use
1:04