The new executive order expands the use of the Bank Secrecy Act in a way that increasingly blurs the line between immigration enforcement and financial surveillance. By encouraging regulators to view ITIN use, foreign consular IDs, and cash-heavy transactions as potential “red flags,” it changes how many financial institutions may assess risk.
For millions of non-citizens, this could mean being viewed as potential suspects before they are seen as ordinary customers. Even individuals who consistently file taxes or operate legitimate small businesses that rely on cash transactions may face greater scrutiny from banks and lenders.