The Order
3.8 million tax filers are now financial risk factors. A new executive order pressures banks to flag every account opened with an ITIN instead of a Social Security Number.
On May 19, President Trump signed “Restoring Integrity to America’s Financial System,” an executive order that turns the banking system into an immigration enforcement tool. It directs the Treasury Department to issue guidance within 90 days telling banks that using an Individual Taxpayer Identification Number instead of a Social Security Number is a red flag for suspicious activity.
The order does not require banks to collect citizenship data. The banking industry fought that version and won. What it does instead is tell regulators to rewrite Bank Secrecy Act rules so that immigration status becomes part of standard customer due diligence. Banks that keep serving ITIN holders face heightened compliance risk. Banks that quietly drop them face nothing.
What the Order Targets
| Red Flag Category | What It Means for Immigrants |
|---|---|
| ITIN used instead of SSN | Checking and savings accounts flagged at opening |
| ”Ability to repay” risk from deportation | Mortgages, auto loans, and credit cards denied or restricted |
| Payroll patterns suggesting off-books wages | Employers and workers both scrutinized |
| Cash structuring and nominee accounts | Routine transactions treated as suspicious |
The White House fact sheet frames this as anti-money-laundering enforcement. But the order’s own text states that lending to people who “face the possibility of the loss of wages due to removal” creates a “structural ability-to-repay deficiency.” That is not about catching criminals. That is about cutting off credit to people the administration plans to deport.
Who Gets Pushed Out
ITIN filers are not hiding from the government. They are filing taxes with it. In 2022, 3.8 million tax returns included ITINs, reporting $14.4 billion in taxable income and $6.5 billion in Social Security and Medicare contributions. These are people paying into systems they cannot draw from.
The National Consumer Law Center warned that this order will produce “debanking on an unprecedented scale.” NCLC deputy director Diane Thompson said it will “radically destabilize the U.S. financial system.” Families pushed out of banks do not stop needing financial services. They turn to cash, check cashers, and predatory lenders that charge more and offer no protections.
The chilling effect extends beyond undocumented immigrants. Legal residents in mixed-status households, DACA recipients, and visa holders all use ITINs or share accounts with people who do. When banks start treating immigration status as risk, the screening does not stop at the undocumented.
The 90-Day Clock
Treasury has 90 days from May 19 to propose new Bank Secrecy Act regulations. That puts the deadline around mid-August 2026. The ABA Banking Journal reports that regulators will also issue formal advisories on the new red flags. Once those land, compliance departments will start adjusting. Account closures and loan denials will follow.
What You Can Do
- Tell your representatives to block implementation. Use Resist Bot to send a letter opposing Treasury rulemaking under this executive order.
- Contact your bank. Ask whether they plan to change account policies for ITIN holders. Put the question in writing.
- If you hold an ITIN account, do not close it preemptively. No rules have changed yet. Document your account history and keep records of tax filings.
- Connect with local legal aid. Organizations like the National Immigration Law Center track these changes and provide guidance.
- Share this brief with immigrant communities, faith organizations, and small business networks that serve ITIN holders.
How This Connects
This order is part of a broader pattern of using federal agencies as immigration enforcement proxies. Tennessee is forcing sheriffs into ICE partnerships. ICE detention operates without meaningful oversight. Now the banking system joins the list. For the full picture, see the Immigration and Detention hub.