On May 20, 2026, President Trump signed an executive order titled “Restoring Integrity to America’s Financial System.”The order directs federal regulators and the Treasury Department to issue new guidance to banks on how to identify customers they suspect are undocumented immigrants.

The practical effect, according to immigration advocates, could be sweeping. People without legal status may lose access to mortgages, credit cards, auto loans, and even basic checking and savings accounts. What was marketed as a financial security measure has set off alarm bells among consumer protection groups and banking experts who warn the order could force millions of people out of the regulated financial system entirely.

In other words, for the first time, the federal government is directing banks to treat immigration status as a financial risk factor. Banks have never collected this information before.

Here’s what we know.

What the Executive Order Actually Requires

The order does not mandate that banks collect citizenship information. According to the American Bankers Association, the order instead directs the Treasury Secretary to issue a formal advisory to financial institutions identifying “red flags and suspicious activity patterns” tied to undocumented immigration. These red flags include, according to a White House fact sheet, repetitive cash withdrawals, the use of shell companies to conceal account ownership, off-the-books wage payments, labor trafficking, and the use of an Individual Taxpayer Identification Number (ITIN) instead of a Social Security Number when opening accounts or obtaining credit.

The order also directs federal financial regulators to propose changes to Bank Secrecy Act regulations. Those changes would strengthen “customer due diligence requirements” and give financial institutions authority to collect additional information “when warranted.” It instructs the Consumer Financial Protection Bureau to consider modifying lending regulations to account for potential deportation and wage loss as factors affecting a borrower’s ability to repay loans. And it directs regulators to issue guidance on managing credit risks of extending financial services to immigrants without work authorization.

What the order does not do—yet—is require banks to verify citizenship status or deny services based on immigration status.

The Undocumented Workforce and the American Economy

To understand the potential fallout from cutting millions of people off from banking, it helps to understand what they actually do and what they contribute.

According to the Center for Migration Studies, approximately 8.3 million undocumented immigrants work in the US economy. They make up 5.2 percent of the total workforce. They are concentrated in industries that are foundational to American life. According to CMS, undocumented immigrants work in construction (1.5 million workers), restaurants (1 million), agriculture and farms (320,000), landscaping (300,000), and food processing and manufacturing (200,000), among other occupations.

What’s more, a Federal Reserve Bank of Dallas study found that immigrant laborers have helped grow the post-pandemic economy, spurring job growth while also helping keep inflation down. According to the Congressional Budget Office, immigrants will add $7 trillion to the economy over the next ten years. The Dallas Federal Reserve estimates that a projected surge of 5.2 million immigrant workers by 2033 will grow the GDP by $8.7 trillion over the same period, with federal taxes increasing by $1.2 trillion and federal deficits decreasing by $900 billion.

Specifically, on taxes, undocumented immigrants who used Individual Tax Identification Numbers paid $59.4 billion in federal taxes. And $13.6 billion in state and local taxes in 2022, according to data from the Center for Migration Studies. They also paid $25.7 billion in Social Security taxes, $6.4 billion in Medicare taxes, and $1.8 billion in unemployment insurance taxes in 2022—for programs from which they are ineligible for benefits.

How This Order Could Backfire

Pushing millions of workers out of the regulated banking system does not eliminate them from the economy. It pushes them into informal finance—cash transactions, wire services, and networks outside federal oversight. This is the opposite of what the White House claims to want.

The administration’s stated goal is to protect the financial system from illicit activity: money laundering, terrorism financing, and human trafficking. Yet forcing undocumented workers out of banks does not prevent illicit activity. It creates the exact conditions where illicit activity thrives. People without access to regulated banking have no choice but to hold cash, use unregulated money transfer services, and participate in the informal economy—precisely the conditions that make financial oversight impossible.

More broadly, the order threatens to destabilize the very industries that depend on this labor. According to the Center for Migration Studies, the construction industry alone faced a shortfall of 500,000 workers in 2025. Agriculture relies on immigrants for over 25 percent of its workforce, and 54.3 percent of agricultural graders and sorters. Healthcare faces a projected shortage of 135,000 workers by 2036, with immigrants currently filling 15.6 percent of nursing positions and 28 percent of healthcare aide slots.

When workers lose access to banking, they lose the ability to build credit, secure mortgages, obtain business loans, and maintain the financial stability necessary to remain in formal employment. According to estimates cited by the Center for Migration Studies, the economic cost of mass deportation is estimated at over $500 billion to implement and would reduce GDP by $5.1 trillion over the next ten years. Cutting undocumented workers off from banking creates similar cascading economic damage without deporting anyone.

The Red Flags Banks Will Look For

According to the White House fact sheet, banks will now be advised to watch for:

  • Repetitive cash withdrawals (suggesting someone is avoiding electronic record-keeping)
  • Use of shell companies to conceal true account ownership
  • Off-the-books wage payments or structuring schemes
  • Labor trafficking indicators
  • Use of ITINs instead of Social Security Numbers
  • Foreign consular identification cards

Now, opening a bank account with an ITIN is not illegal. ITINs were created specifically to allow people to file and pay taxes. But under this order’s framing, the act of using an ITIN instead of an SSN becomes a “red flag” for financial institutions to investigate.

How to Think About Protecting Yourself

The National Consumer Law Center, immigration attorneys, and advocacy organizations are still developing guidance. This is due in part to regulators not yet having issued guidance for banks to follow.

However, immigration advocates have identified several concerns:

Financial transparency: The order directs regulators to strengthen the authority of banks to collect additional information “when warranted.” Immigration attorneys have warned that providing extensive financial documentation could expose people to scrutiny. That said, refusing to provide documentation when asked is also risky and could result in account closure.

Cash management: One practical concern raised by advocates is that people may be tempted to withdraw cash and hold it to avoid scrutiny. According to the White House, repetitive cash withdrawals themselves are now flagged as suspicious activity. This creates a catch-22: keeping money in a bank creates a digital trail that could trigger an investigation; withdrawing it creates the suspicious activity pattern the order aims to identify.

ITIN account status: People who currently hold accounts opened with ITINs should not assume those accounts are automatically at risk. Banks were already treating ITIN holders with caution before this order. What changes is the level of regulatory guidance and potential pressure on banks to scrutinize these accounts more intensively. Immigration attorneys have advised people to maintain accurate records showing legitimate income sources if they hold accounts with ITINs.

Seek expert counsel: Immigration advocates, legal organizations, and the American Immigration Lawyers Association are developing detailed guidance as regulators issue formal direction to banks. Local immigrant advocacy organizations may provide clearer direction sooner.

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