The Financial Crimes Enforcement Network today issued an advisory warning financial institutions “to be vigilant against risks presented by the unlawful employment of illegal aliens.” The advisory was jointly issued with the FDIC, Office of the Comptroller of the Currency, National Credit Union Administration and IRS.
Last month, President Trump directed regulators to provide guidance to financial institutions on identifying suspicious activity allegedly tied to undocumented immigrants. The FinCEN advisory lists methodologies, financial typologies and red flags associated with illegal immigration.
In addition, the advisory highlights how labor brokers may use a foreign identity document — such as a foreign passport — or an Individual Taxpayer Identification Number, or ITIN, to open the account for the shell company at a bank. The document encourages banks to consider the use of an ITIN when applying appropriate risk-based procedures for customer due diligence, in light of the totality of other factors and available information, according to a statement.
“Non-work authorized populations and their employers often rely on access to the U.S. financial system,” the advisory states. “In certain instances, the access to financial services and unlawfully obtained wages can be leveraged to facilitate the financing of transnational criminal organizations — several of which have been designated as Foreign Terrorist Organizations — and their global criminal enterprises, including drug trafficking, human trafficking and other illegal activity in the United States.”
