The U.S. Department of the Treasury’s Financial Crimes Enforcement Network issued an advisory on June 5, 2026, calling on financial institutions to identify and report suspicious activity tied to the unlawful employment of illegal aliens.
The advisory, released jointly with the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the National Credit Union Administration, and coordinated with the Internal Revenue Service, urges banks and other regulated entities to remain alert to payroll fraud and identity theft schemes that channel unlawful wages through the U.S. financial system, according to a statement released by the Treasury.
“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 Treasury Secretary Scott Bessent. “This Administration will not allow illegal aliens to abuse financial institutions to steal billions of dollars from hardworking American taxpayers.”
FinCEN said the guidance supports Executive Order 14406, titled Restoring Integrity to America’s Financial System. The agency warned that employers who hire and conceal non-work-authorized workers can undercut lawful U.S. businesses, suppress wages, enable identity theft against Americans, and divert tax revenue intended for government benefit programs.
According to the advisory, unlawfully obtained wages can also help finance transnational criminal organizations, several of which have been designated as Foreign Terrorist Organizations. Those proceeds, the agency said, may support drug trafficking, human trafficking, and other illicit activity inside the United States. One case study cited in the advisory described two foreign national fraudsters who ran a multi-year payroll scheme involving illegal alien workers that cost the United States more than $38 million.
Payroll Fraud and Shell Companies
The advisory focuses on identity theft and payroll fraud used by complicit employers in industries such as agriculture, construction, domestic service, and hospitality. FinCEN said illegal aliens can obtain Social Security numbers and other personal information belonging to U.S. citizens and lawful permanent residents to secure jobs, wages, health benefits, and access to financial services.
In 2025, financial institutions filed reports identifying more than $2.5 billion in suspicious activity linked to payroll tax fraud schemes, according to the advisory.
FinCEN also described the role of complicit labor brokers, who it said often establish shell companies that operate as unregistered money services businesses. Those entities provide off-the-books payroll services for employers and their unlawful workers. Brokers may use a foreign passport or an Individual Taxpayer Identification Number (ITIN) to open shell company accounts at banks, the advisory said. Employers then send checks to the shell companies under the guise of payment for services or products, and the broker launders the funds before distributing payments to workers through cash couriers, checks, or peer-to-peer platforms, without withholding federal or state payroll taxes.
ITINs and Reporting
The advisory encourages banks to consider an ITIN as a potential risk factor when it is presented in place of a Social Security number or a valid employment authorization document to open accounts or obtain credit products.
FinCEN included 18 red flag indicators to assist institutions in detecting related schemes. The agency asked filers to reference the key term “FINANCIALINTEGRITY-2026-A002” in Suspicious Activity Report field 2 and in the narrative. FinCEN also encouraged the public to report tips about employers who knowingly employ or exploit unauthorized workers to Immigration and Customs Enforcement.
