Banking and Finance Law Daily Wrap Up, CRIMES AND OFFENSES—Nonprofit sends FOIA requests to nine agencies on illegal alien access to banking system, (Mar 24, 2026)

By Lauren Bikoff, MLS

The Federation for American Immigration Reform intends to investigate illegal aliens’ access to the U.S. banking system to provide the Trump administration with policy recommendations.

The Federation for Immigration Reform (FAIR) has sent Freedom of Information Act (FOIA) requests to nine federal agencies to gather information on illegal aliens’ use of U.S. banking services. According to the nonprofit organization, “Participation in America’s banking system is a privilege reserved for U.S. citizens and legal immigrants—not a loophole for those here illegally.” FAIR’s investigation seeks to deliver concrete findings and provide recommendations to Congress and the Trump administration for banking system reform.

“Banking is not a right for illegal aliens—it is a privilege that demands strict accountability to protect the rule of law and national security,” said Dale Wilcox, FAIR’s executive director and general counsel. “These FOIAs should reveal how federal regulators have failed to close this dangerous loophole.”

Citing the Trump administration’s focus on lawful presence, including Executive Order 14159 and the Financial Crimes Enforcement Network’s (FinCEN) FIN-2025-Alert003 (see Banking and Finance Law Daily, Dec. 1, 2025), the organization intends to quantify the scale of foreign-ID account abuse, uncover ignored internal warnings, and build a case for reforming the Customer Identification Program rules under the Bank Secrecy Act.

FOIA requests were sent to the Consumer Financial Protection Bureau, the Federal Deposit Insurance Corporation, the Federal Reserve Board, FinCEN, the Office of the Comptroller of the Currency, the National Credit Union Administration, the Internal Revenue Service, the U.S. Immigration and Customs Enforcement, and the Department of the Treasury. The requests seek communications, policies, examination reports, enforcement actions, Suspicious Activity Reports, data concerning Individual Taxpayer Identification Number (ITIN)-only accounts, and records regarding the acceptance of foreign documents to receive financial services (including passports, Matrícula Consular cards, and foreign national IDs). FAIR has requested access to all related documents dated Jan. 1 to Mar. 1, 2026.

Companies: Federation for American Immigration Reform

RegulatoryActivity: BankSecrecyAct BankingOperations CFPB CrimesOffenses DepositInsurance FederalReserveSystem OversightInvestigations