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.
Published 2026/06/25