WASHINGTON—Today, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an Advisory urging financial institutions to be vigilant against risks presented by the unlawful employment of illegal aliens.
“President Trump has done more than anyone in history to secure our nation’s borders. Part of that effort includes securing our financial system,” said Secretary of the Treasury Scott Bessent. “This Administration will not allow illegal aliens to abuse financial institutions to steal billions of dollars from hardworking American taxpayers.”
By hiring, concealing, and exploiting non-work authorized populations, employers can gain an unfair advantage over legitimate U.S. businesses, depress wages, facilitate identity theft of Americans, and steal tax revenue meant for government benefit programs. Schemes to pay unlawful workers often rely upon access to the U.S. financial system, including U.S. banks. Unlawfully obtained wages can be leveraged to facilitate the financing of transnational criminal organizations—several of which have been designated as Foreign Terrorist Organizations—and their global criminal enterprises, including drug trafficking, human trafficking, and other illicit activity in the United States. In one case study described in the Advisory, two foreign national fraudsters conspired to operate a years-long payroll scheme that employed undocumented aliens working illegally and cost the United States more than $38 million.
FinCEN issued this Advisory jointly with the Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, and National Credit Union Administration and in coordination with the Internal Revenue Service. This Advisory supports Executive Order 14406, Restoring Integrity to America’s Financial System, and Treasury’s continued effort to prevent the exploitation of the U.S. financial system by illegal aliens in the United States.
Financial Institutions are Critical to Detecting and Reporting Illicit Activity Related to Non-Work Authorized Populations
The Advisory calls attention to identity theft and payroll fraud as key features in schemes by complicit employers in the agriculture, construction, domestic service, hospitality, and other industries to conceal violations of U.S. immigration laws.
- Unlawful aliens can illicitly obtain Social Security numbers and other personally identifiable information of U.S. citizens and lawful permanent residents to gain unlawful employment and wages, employer- and government-provided health care benefits in the United States, and access to financial services.
- Complicit employers can also use payroll tax fraud schemes to conceal their hiring of low-wage unlawful alien workers, as well as to evade taxes and workers’ compensation benefits.
- In 2025, financial institutions reported over $2.5 billion in suspicious activity associated with these payroll tax fraud schemes.
The Advisory also highlights how these schemes involve a complicit labor broker who sets up a shell company, often an unregistered money services business providing off-the-books payroll or payment processor services for complicit employers and their unlawful alien workers.
- FinCEN’s analysis highlights how complicit labor brokers may use a foreign identity document—such as a foreign passport—or an Individual Taxpayer Identification Number (ITIN) to open the account for the shell company at a bank.
- Complicit employers send checks to these shell companies for purported services or products related to their industry.
- The complicit labor broker then launders the funds and sends payments to the unlawful alien workers on behalf of the complicit employers through (i) cash couriers, (ii) checks, or (iii) peer-to-peer platforms without withholding any Federal and state payroll taxes for either the unlawful alien workers or their employers.
Enhanced Due Diligence for Individual Taxpayer Identification Numbers (ITINs)
The Advisory encourages banks to consider the use of an ITIN when applying appropriate risk-based procedures for customer due diligence, in light of the totality of other factors and available information. Specifically, when an ITIN is presented in lieu of a Social Security number or valid employment authorization document to obtain credit products or open an account, banks are encouraged to assess whether the use of an ITIN may be a relevant risk factor.
Reporting Suspicious Activity
The joint Advisory includes 18 red flag indicators to help financial institutions detect, prevent, and report suspicious activity connected to fraud schemes involving the unlawful employment of unlawful aliens. FinCEN requests that financial institutions use the key term “FINANCIALINTEGRITY-2026-A002” in SAR field 2 (Filing Institution Note to FinCEN) and the narrative to indicate a connection between the suspicious activity being reported and the activities highlighted in this Advisory. In addition to filing a Suspicious Activity Report, FinCEN encourages financial institutions and the public to report any tips or complaints about employers that knowingly employ and/or exploit unauthorized workers to Immigration and Customs Enforcement’s Tip Form or by calling (866) 347-2423.
FinCEN’s Advisory Program
The Financial Crimes Enforcement Network’s Advisory Program communicates priority money laundering, terrorist financing, and other illicit finance threats and vulnerabilities to the U.S. financial system. Financial institutions may use this information to support effective, risk-based, and reasonably designed AML/CFT programs and suspicious activity monitoring systems to help generate highly useful information for law enforcement and national security agencies. FinCEN’s Advisory Program has resulted in highly useful Suspicious Activity Reports that have helped law enforcement and national security agencies “follow the money” to uncover and disrupt criminal activity, protect the U.S. financial system, and hold illicit actors accountable.
FinCEN’s Whistleblower Program
FinCEN maintains a whistleblower program to encourage reporting on violations of the Bank Secrecy Act and certain sanctions and national security laws. Individuals who provide actionable information may be eligible for awards if their tip leads to a successful enforcement action. FinCEN encourages individuals with relevant information to submit whistleblower tips and learn more about FinCEN’s Whistleblower Program at www.fincen.gov/whistleblower-program.
Financial Institution:
Casinos
Depository Institutions
Insurance Industry
Money Services Businesses
Mortgage Co/Broker
Precious Metals/Jewelry Industry
Securities and Futures
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