Executive Order 14406: The 90-Day Customer Due Diligence Deadline

On 19 May 2026, the White House issued Executive Order 14406, “Restoring Integrity to America’s Financial System.” The order imposes a 90‑day deadline, set for 17 August 2026, for the Treasury, alongside federal regulators, to propose updates to Bank Secrecy Act (BSA) regulations, fundamentally tightening Customer Due Diligence (CDD) protocols to strengthen nominal and beneficial ownership identification and reduce cross‑border illicit finance risks.  

The primary directive of EO 14406 requires lenders, banks and financial institutions to incorporate citizenship and work authorisation status directly into their risk management and due diligence procedures. It introduces significant underwriting reforms, linking deportation risk directly to evaluations of a borrower’s repayment ability. The 90‑day deadline requires the Secretary of the Treasury to present formal amendments to the BSA to reinforce these requirements. 

• Enhanced Customer Identification Programs (CIP): Institutions must collect and verify immigration status information when relevant to assessing exposure to fraud, money laundering or sanctions violations.  

• The Use of ITINs: The order identifies Individual Taxpayer Identification Numbers (ITINs) as a potential risk factor. While useful for tax compliance, institutions must apply enhanced due diligence when an ITIN is used in place of a Social Security Number or a verified work visa.  

• Employer Red Flags: Institutions must prepare to identify irregular payroll structures, sub-threshold cash processing and shell companies that mask labour practices to obscure beneficial owners.  

Strategy Over Friction

The shifting landscape of regulatory frameworks concerning national origin and immigration status demands more than reactive, checklist-driven compliance protocols. Forward-looking, strategy-first governance is necessary.  

Ahead of the Treasury’s formal rule proposals, institutions should immediately review current underwriting policies for immigration-related credit risks, prepare ITIN infrastructure and verify that third-party vendors are aligned with the new heightened KYC/AML expectations.   

Rely on the Experts, Focus on Growing Bolder

Navigating tightened and complex CDD requirements shouldn’t impede your business operations. At Bolder, we help you mitigate regulatory friction and maintain compliance resilience. We handle the behind-the-scenes work, from governance solutions to ongoing compliance risk management, so you can focus on what matters most: growing your business.  

Let’s work together to ensure your Customer Due Diligence frameworks are prepared for the post-EO 14406 landscape.  

Connect with Bolder Group today to speak with our governance and compliance experts.