Restoring Integrity to America's Financial System
- Executive Order Number
- 14406
- President
- Donald Trump
- Signed
- May 19, 2026
- Published
- May 22, 2026
- Source
- Federal Register
- Original Document
- https://www.govinfo.gov/content/pkg/FR-2026-05-22/pdf/2026-10400.pdf
AI-Generated Summary
Executive Order Summary: Safeguarding the U.S. Financial System from Illicit Use by Inadmissible and Removable Aliens
Purpose
The executive order establishes a policy to protect the U.S. financial system from exploitation by inadmissible or removable aliens and non-work-authorized populations. It aims to mitigate risks of illicit finance (including terrorism financing, narcotics and human trafficking, money laundering, and payroll tax evasion), address structural credit risks in lending, and reinforce Bank Secrecy Act (BSA) compliance to promote safety and soundness of financial institutions.
Key Actions or Directives
- Treasury Advisory (60 days): The Secretary of the Treasury must issue guidance to financial institutions detailing red flags and typologies for suspicious activity tied to non-work-authorized individuals, such as payroll tax evasion, use of shell companies or foreign-identity documents, structuring transactions, labor trafficking indicators, and ITIN misuse for accounts or credit.
- BSA Due Diligence Rule Changes (90 days): Treasury, in consultation with Federal functional regulators, must propose amendments to strengthen risk-based customer due diligence, including verification of beneficial owners and authority to collect immigration status and work authorization information when relevant to compliance risks.
- Customer Identification Program Updates (180 days): Treasury and regulators must consider revisions to customer identification requirements, specifically addressing risks from foreign consular identification cards.
- Credit Risk Guidance (60 days): The Consumer Financial Protection Bureau (CFPB) must consider clarifying that potential deportation and wage loss are factors affecting ability-to-repay determinations under Regulation Z (12 CFR Part 1026). Federal functional regulators must issue guidance on managing credit risks from the non-work-authorized population.
- Definition: “Federal functional financial regulator” is limited to the Federal Reserve, OCC, FDIC, and NCUA.
Significant Changes to Policy or Law
The order integrates immigration enforcement considerations into BSA/AML frameworks and consumer credit underwriting. It explicitly links lack of lawful immigration status or work authorization to heightened financial crime and credit risks, directing agencies to treat these factors as potential red flags or underwriting concerns without creating new statutory authorities.
Potential Impacts
- Financial Institutions: Increased compliance obligations for customer identification, enhanced due diligence, and monitoring, potentially raising operational costs and affecting account access or lending decisions for certain populations.
- Regulated Entities and Borrowers: Possible tightening of credit availability (mortgages, auto loans, credit cards) for non-work-authorized aliens due to ability-to-repay concerns.
- Government Agencies: Expanded rulemaking and guidance responsibilities for Treasury, CFPB, and the four Federal functional regulators.
Main Stakeholders Affected
- Federal functional financial regulators and the Department of the Treasury
- Banks, credit unions, and other covered financial institutions
- Non-work-authorized and inadmissible/removable alien populations
- Employers and labor brokers interacting with these populations
Notable Legal, Constitutional, or Political Implications
The order operates within existing BSA and consumer protection authorities and explicitly preserves agency discretion and statutory limits. It does not create enforceable private rights and is subject to appropriations and applicable law. Implementation may raise questions regarding the scope of BSA customer due diligence requirements and the use of immigration status in financial risk assessments.
This summary was generated by AI and may contain inaccuracies. Refer to the official source document for the authoritative text.