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Podcast Episode

Understanding bank regulators' guidance on illegal immigration

ABA Banking Journal Podcast··16 July 2026·14 min

About this episode

On the latest episode of the ABA Banking Journal Podcast, ABA's Heather Trew breaks down recent news about the president's executive order on illegal immigration and the financial system and the advisory from the Financial Crimes Enforcement Network, the OCC, the FDIC and others on red flags associated with illegal immigration. Trew covers: An overview of the executive order and advisory Financial typologies of suspicious activity linked to illegal immigration that FinCEN has identified — for individual consumers, small businesses and large businesses Scrutiny on the use of individual taxpayer identification numbers, or ITINs, to open accounts, and the technical complexities of differentiating between ITINs and other identifiers How banks can stay in the loop on developments, particularly future changes to the customer due diligence and customer identification program rules