In the July issue of our magazine, Banking on BCC, we discussed the Joint Advisory on Non-Work Authorized Populations and Their Employers and Risks to the Integrity of the U.S. Financial System (FIN-2026-A002), which was issued by FinCEN on June 5, 2026. The Advisory directed 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.
Not to be outdone, the FDIC, OCC and NCUA issued Interagency Guidance on Lending to Individuals Not Authorized to Work in the United States on July 13th. The Guidance reminds financial institutions about …their existing obligations with respect to credit risk management, particularly as it relates to borrowers who are not legally authorized to work in the United States (non-work authorized borrowers). The Guidance outlined five key underwriting areas that financial institutions should consider. These included:
- Source of Repayment
- Collateral Considerations
- Documentation and Verification
- Portfolio and Concentration Considerations
- Consumer Compliance Risk
If you want to learn more, be sure to check out our webinar, “FinCEN Advisory: Non-Work Authorized Populations”, which is available now OnDemand.
Published 2026/07/30
