USA executive order flags ITIN accounts as risk factor for nomads

What the executive order actually does

President Donald Trump signed an executive order titled "Restoring Integrity to America's Financial System" directing the Treasury Department and federal financial regulators to treat a customer's immigration status as a risk factor under existing Bank Secrecy Act rules. The order doesn't create a nationwide freeze on non-citizen or Individual Taxpayer Identification Number (ITIN) accounts, despite headlines suggesting otherwise.

Treasury and the Financial Crimes Enforcement Network must now draft guidance flagging risks like money laundering, payroll tax evasion, shell companies and "use of ITINs for account openings or credit acquisition without validated legal status." Reuters reported the order is narrower than an earlier Treasury proposal that would have required citizenship data from every banking customer. Most operational changes depend on a future notice-and-comment rulemaking, not the signing itself.

Who gets flagged

The clearest targets are ITIN-only customers with no SSN or work authorization, especially accounts showing cash-heavy activity, payroll flows from employers under scrutiny or links to shell entities. Foreign consular ID cards are singled out as a red flag, though foreign passports remain accepted under existing Know Your Customer (KYC) rules.

Lawfully present expats and digital nomads who use ITINs because they file U.S. taxes without an SSN sit in a grayer zone. Nothing in the order targets them specifically, though banks running enhanced due diligence may request updated passports, visas or proof of lawful presence during routine file reviews. Green card and work visa holders aren't the focus, but updated documentation requests are likely.

Tourist visa holders rarely open U.S. accounts and aren't addressed beyond standard KYC.

What account holders should do

Non-citizen account holders, particularly ITIN users, should expect more frequent "update your documents" requests and prepare current identification before banks ask:

• A valid passport and any current U.S. visa or work authorization
• Proof of U.S. address and tax filings tied to the ITIN
• Documentation of income sources for unusual deposits

A separate bill in Congress would require banks to verify legal immigration status outright. It hasn't passed. Account closures under "de-risking" remain a bank-by-bank decision, so customers with complex profiles may want to keep a backup account at a second institution.

Read our full USA guide for the complete picture and follow ongoing visa updates as Treasury rules take shape.