FinCEN’s New Advisory Reads Like AML Guidance. It Functions Like Immigration Enforcement.
Last Friday, FinCEN handed banks 18 new red flags, a SAR key term, and a direct tip line to ICE. The advisory is framed as payroll fraud guidance, and the fraud is real, but read alongside EO 14406 and the CFPB’s new statement on immigration status, it amounts to something bigger: financial institutions being drafted into immigration enforcement. I broke down what’s actually in FIN-2026-A002, what it means for compliance teams, and what belongs on your agenda before month end.
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