Update 5/20/25: An executive order has now been signed. This is less extensive than the previous proposal. Rather than requiring citizenship data it directs the treasury issue a formal Advisory within 60 days to financial institutions regarding ‘ risks associated with the exploitation of the United States financial system by non-work authorized populations and their employers’. Specifically looking at:
“(i) evidentiary patterns of payroll tax evasion by employers or labor brokers, including the systematic failure to withhold or remit Federal employment taxes for non-work authorized individuals;
(ii) the utilization of certain foreign-identity documents, nominee accounts, shell companies, or complex “funnel” structures designed to obfuscate the identity of the ultimate beneficial owners or conceal the true nature of payroll disbursements;
(iii) the strategic use of unregistered money services businesses, third-party payment processors, or peer-to-peer platforms to facilitate “off-the-books” wage payments intended to bypass Bank Secrecy Act reporting thresholds or tax obligations;
(iv) patterns of repetitive, sub-threshold cash withdrawals or deposits that correlate with payroll cycles conducted outside of regulated payroll processing systems, also known as “structuring and micro-structuring”;
(v) financial activity indicative of labor trafficking or forced labor (as defined in 18 U.S.C. 1589), where proceeds are commingled with legitimate business revenue or transferred to foreign jurisdictions; and
(vi) the use of an individual taxpayer identification number (ITIN) to obtain credit products or open depository accounts where the applicant lacks verified lawful immigration status. Although an ITIN facilitates tax compliance, its use in lieu of a Social Security number or valid work-authorized visa may be identified as a risk factor requiring enhanced due diligence to ensure the account is not being utilized to facilitate the unlawful employment of unauthorized aliens.”
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Update 4/14/26: This is reportedly in process with Scott Bessent saying that a proposed executive order that would require banks to collect this information is “in process”.
Original post: 2/24/26: The Trump Administration is considering requiring banks to collect proof of citizenship (e.g passports) according to WSJ & Semafor. If implement the policy would be retroactive meaning banks would need to collect this information from existing accountholders. The order would be via president order, not legislation.
Financial institutions have already pushed back on the news saying that it’s unworkable, with many account holders not having this information on hand. I assume nothing will actually come from this and some other concession will be given instead. For example President Trump called for a cap on credit card interest rates of 10%, then Visa said rewards would be able to be deposited into so called ‘Trump Accounts’ and we haven’t heard much about interest rate caps again.
Additional document requirements would likely be costly for financial institutions as well, this could erode bank account bonuses, remove benefits and increase fees.
