The short version
On May 20, 2026, President Trump signed an executive order titled Restoring Integrity to America's Financial System. The order directs the Treasury Department and federal bank regulators to issue new guidance treating a customer's immigration status as a factor in evaluating risk under the 1970 Bank Secrecy Act. It also tells regulators to look more closely at ITIN-based accounts, third-party payment platforms, payroll-tax evasion, and "strategic" use of unregistered money services.
It does not require banks to collect citizenship information from every customer — that requirement was in an earlier draft and was dropped after industry pushback. It does not close any existing accounts. The practical effects will arrive later, through Treasury and regulator guidance.
What the executive order actually does
The order tells federal financial regulators — including the Office of the Comptroller of the Currency, the Federal Reserve, and the FDIC — to update their guidance to banks on how to evaluate "potential risks" under existing anti-money-laundering law. The specific activities the order asks regulators to flag include:
The flagged activities, as written in the order
- Payroll-tax evasion
- Attempts to conceal a customer's identity
- "Strategic" use of unregistered money services businesses or third-party payment platforms
- Labor trafficking or forced labor
- Use of an Individual Taxpayer Identification Number (ITIN) to obtain credit or open an account
- Patterns of transactions associated with money laundering or terrorism financing
The reference to ITINs is the one that has drawn the most attention, because the IRS issued more than 26 million ITINs to people without an SSN — many of them undocumented workers — over the program's lifetime. An ITIN is, by design, the IRS's way of letting non-citizens pay U.S. taxes. The order treats the same number that lets you file taxes as a possible risk signal when you sit down at a bank to open an account.
An ITIN is a nine-digit tax-processing number the IRS issues to people who must file U.S. taxes but are not eligible for a Social Security Number. Having an ITIN is not, by itself, evidence of immigration status — some ITIN holders are undocumented, others are dependents on visas, foreign students, or non-resident investors. The order does not change that, but it does ask banks to think about it.
What was dropped from the order
An earlier proposal that circulated in the spring would have required banks to collect citizenship information from every customer — new and existing. Banking industry groups, including the American Bankers Association, opposed it on cost and operational grounds: collecting and storing citizenship data for hundreds of millions of accounts would be a massive operational lift, and would expose banks to discrimination claims.
That mandatory citizenship-collection requirement was removed from the version Trump signed. Instead, banks are asked to apply existing Bank Secrecy Act tools — Customer Identification Program checks, Suspicious Activity Reports, enhanced due diligence — with new attention to the list of activities above.
What this means for ITIN holders today
Three things are true at the same time, and it's worth keeping them separate:
| Question | The honest answer |
|---|---|
| Is my existing ITIN account closed? | No. The order does not order any account closed. Existing accounts stay open. Banks may, however, ask updated questions if they review your account file. |
| Can I still open a new bank account with an ITIN? | Yes. Bank of America, Chase, Citibank, and Wells Fargo continue to accept ITIN customers at branches. The process — apply in person, bring ITIN, passport or photo ID, and proof of address — is unchanged. |
| Will it be harder to open an account going forward? | Possibly. Expect staff to take longer to verify documents and ask more questions about source of funds, employer, and address history. Bring more documentation than you think you need. |
| Will my deposits be reported to ICE? | The order does not direct banks to share customer information with immigration enforcement. It directs banks to file Suspicious Activity Reports — the same SARs they have filed for decades — when activity matches the flagged patterns. |
Four things to do this week
1 · Keep your ITIN active by filing taxes
An ITIN that is used on a tax return at least once every three years stays active. A taxpaying ITIN holder is the cleanest profile to present to any bank reviewing your account. If you have not filed for a year you owe a return on, file it. See how to file taxes with an ITIN.
2 · Keep your identity documents organized
Have ready: your IRS ITIN assignment letter (CP565), a valid passport, and two recent proofs of U.S. address (utility bill, lease, bank statement). If your passport is close to expiring, renew it now. If you've moved, update your address with your bank.
3 · Don't move money around to "look smaller"
The single fastest way to trigger a Suspicious Activity Report is a pattern of cash deposits or transfers just under the $10,000 reporting threshold — a practice the rules already call "structuring." Don't break a normal deposit into smaller ones to avoid reporting. Normal use of your account is not the problem; trying to look smaller is.
4 · Use established banks over app-only fintechs
The big four banks (Bank of America, Chase, Citibank, Wells Fargo) have long-standing processes for ITIN customers and trained branch staff. Some app-only neobanks still don't accept an ITIN at all, and others have inconsistent policies. For now, the in-person path at a major bank is the most predictable. See the best banks for ITIN holders.
The fintech executive order, briefly
On May 19 — the day before — Trump signed a different financial order, Integrating Financial Technology Innovation into Regulatory Frameworks. That order is about opening the financial system, not tightening it: it directs the Federal Reserve to review the legal and policy framework for letting fintech firms and non-bank financial companies access Federal Reserve payment accounts. Regulators have 90 days to identify barriers and 180 days to act on them.
For ITIN holders the two orders pull in opposite directions. The May 20 order tells banks to look harder at ITIN customers. The May 19 order, over time, could let more fintech firms onto the rails that move money — and a wider set of fintechs may eventually accept ITIN customers. Neither effect is visible today; both will play out in the coming year through agency guidance.
How we'll cover this going forward
This is a news section on a guide site. The substance of what changes — for opening a bank account, for keeping one, for sending money abroad, for getting a credit card — lives in our long-form guides, which we update as Treasury and bank regulators publish actual rules. When that guidance lands, you'll see it summarized here and reflected on the underlying guide page.
Not legal advice
This article summarizes a federal executive order in plain language. It is not legal or tax advice. If you have a specific concern about your immigration status, a bank inquiry about your account, or a tax matter, consult a licensed immigration attorney or a credentialed tax professional.
Sources
- whitehouse.gov — Presidential Actions (executive order text and fact sheet)
- TIME — Treasury Secretary Bessent on bank citizenship information
- Semafor — Citizenship-collection requirement dropped from final order
- National Consumer Law Center — Advocacy response
- Consumer Finance Monitor — Fintech executive order analysis
- IRS — ITIN program page