Restoring Integrity to America's Financial System

The order directs the Secretary of the Treasury to issue a formal advisory within 60 days describing red flags and suspicious-activity patterns tied to non-work-authorized populations and their employers, including payroll tax evasion, use of foreign identity documents, structuring, and ITIN-based account activity. Within 90 days, Treasury must propose Bank Secrecy Act regulatory amendments to strengthen risk-based customer due diligence, including authority to collect immigration-status information when it is relevant to fraud or illicit-finance risk. Within 180 days, Treasury and the functional regulators must consider further changes to customer identification program rules, including risks posed by foreign consular ID cards. In parallel, the CFPB and each federal functional financial regulator must — within 60 days — consider guidance clarifying that deportation risk and wage loss are relevant to ability-to-repay lending standards.

The order does not itself change any regulation, create any new legal obligation on financial institutions, or alter the Bank Secrecy Act. All operative impacts depend on the advisory, proposed rules, and guidance that agencies are directed to produce. A standard clause explicitly states the order creates no enforceable rights against the government.

Banks, credit unions, mortgage lenders, and other financial institutions covered by Bank Secrecy Act rules and consumer lending regulations. Individuals without lawful work authorization who hold or seek U.S. bank accounts or consumer credit products. Employers who use ITINs or non-standard payroll arrangements.

Financial institutions may face new compliance burdens around customer identification and loan underwriting tied to immigration status. Non-work-authorized individuals could find it harder to open accounts or obtain credit if regulators adopt guidance treating immigration status as a risk factor requiring enhanced scrutiny.

Treasury fires first — a red-flag advisory within 60 days — then must propose BSA due-diligence rule changes within 90 days and consider customer-identification program amendments within 180 days. CFPB and the four functional regulators work on a parallel 60-day track for credit-risk guidance. Because every substantive step is an advisory, proposed rule, or "consider clarifying" directive, actual regulatory changes require future notice-and-comment rulemaking before they bind any institution. There are no explicit enforcement teeth for missed deadlines, and the order contains a standard no-private-rights-of-action clause.