On May 19, 2026, the President of the United States of America, Donald J Trump, signed an Executive Order, “Restoring Integrity to America’s Financial System,” that expands customer due diligence expectations and enhances financial transparency requirements. 

While early discussions focused on whether financial institutions would be required to collect proof of citizenship from all customers, the final order took a different approach that may ultimately have a broader impact on an institution’s anti-money laundering and countering the financing of terrorists (AML/CFT) program across the money services business (MSB) industry.

Ultimately, the Executive Order has initiated a regulatory review process that could significantly reshape existing Bank Secrecy Act (BSA) and AML/CFT compliance expectations for MSBs for the first time since the Anti-Money Laundering Act of 2020 (AML Act of 2020).

A Shift Toward Financial Crime Risk Detection 

According to the White House Fact Sheet issued alongside the Executive Order, Treasury has been directed to issue formal advisories identifying suspicious activity patterns tied to:

• Payroll tax evasion
• Concealment of true account ownership
• Off-the-books wage payments
• Structuring schemes
• Labor trafficking
• Use of Individual Taxpayer Identification Numbers (ITINs) (without immigration documentation)

The Order further directs Treasury and federal financial regulators to propose revisions to BSA regulations that would:

• Strengthen Customer Due Diligence (CDD) requirements
• Expand authority to obtain additional customer information when warranted
• Enhance the ability to identify the true owners of accounts
• Improve risk assessments tied to unlawful financial activity

This represents a meaningful shift toward integrating immigration-related indicators into existing AML/CFT controls.

Current MSB Customer Identification Requirements

Today, MSBs operate under Customer Identification Program (CIP) and Know Your Customer (KYC) requirements established under the BSA and administered by the Financial Crimes Enforcement Network (FinCEN).

MSBs are generally required to collect and verify:

• Customer name
• Residential or business address
• Date of birth (where applicable)
• Taxpayer Identification Number (ITIN) or Social Security Number (SSN)
• Government-issued identification

These requirements support broader AML/CFT obligations, including:

• Suspicious Activity Report (SAR) monitoring
• Customer risk rating
• Enhanced Due Diligence (EDD)
• Ongoing transaction monitoring
• Recordkeeping and reporting requirements

Importantly, federal rules do not currently require MSBs to independently verify citizenship or immigration status as part of routine onboarding procedures.

However, the May 19th Executive Order signals that regulators are preparing to expand the incorporation of immigration-related risk factors into AML/CFT expectations.

The Shift Away From Universal Citizenship Verification

Early discussions about universal citizenship verification raised major operational concerns across the financial services industry, particularly for high-volume transactional businesses such as MSBs and banks.

For money transmitters and retail financial service providers, implementing blanket citizenship verification requirements could have significantly disrupted:

• Customer onboarding
• Remittance processing
• Agent operations
• Frontline transaction workflows
• Document retention procedures
• Customer service delivery

MSBs process large transaction volumes across diverse customer populations, often within fast-paced retail environments. A universal documentation mandate would likely have created substantial operational burdens without necessarily improving risk-based AML detection.

The final Executive Order instead adopted a more targeted approach focused on strengthening existing AML/CFT controls, customer due diligence expectations, and the identification of suspicious activity.

What MSBs Should Expect Next

Although the Executive Order does not immediately change existing CIP regulations, it creates a strong possibility of future regulatory updates.

MSBs should anticipate potential developments in several areas:

Enhanced Customer Due Diligence Expectations

Treasury may issue guidance requiring institutions to incorporate additional risk indicators tied to:

• ITIN usage patterns
• Cross-border remittance activity
• Labor-intensive industries
• Third-party transaction behavior
• High-risk geographic corridors
• Expanded EDD Procedures

For MSBs, higher-risk customer relationships may require more sophisticated transaction monitoring technologies, stricter automated rule-sets, stronger customer data integrity controls, enhanced escalation procedures, and expanded supporting documentation under the proposed revised CDD standards.

Revisions to AML/CFT Policies and Procedures

MSBs may need to update:

• Customer onboarding procedures
• Risk-rating methodologies
• SAR escalation protocols
• Customer review processes
• CIP and KYC documentation standards

Federal and state examiners may begin evaluating whether MSBs have adequately incorporated emerging indicators of immigration-related financial crime into their AML/CFT programs.

A New Phase of AML/CFT Compliance

The May 19th Executive Order signals a broader regulatory evolution within the MSB industry.

Institutions that proactively review their AML/CFT program, EDD procedures, KYC policies, and customer risk assessment frameworks will be in the strongest position as Treasury and regulators begin proposing revisions to existing BSA requirements. If you would like support with updating your AML/CFT compliance systems, contact us.

Tags: AML, AML/CFT Program, Anti Money Laundering, CDD, CFT, Countering the Financing of Terrorism, Customer Due Diligence, FinCEN, Know Your Customer, KYC, Money Services Business, MSB, SAR, Suspicious Activity Report