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FinCEN Warns of Financial Crime Risks in Unauthorised Labour

15 June 2026

FinCEN Warns of Financial Crime Risks in Unauthorised Labour

The Financial Crimes Enforcement Network (FinCEN) issued a joint advisory on non-work authorised populations. 

 

 

Key insights include:

➡️ Identity Theft Risks: FinCEN highlights schemes involving stolen Social Security Numbers (SSNs) and other Personally Identifiable Information (PII) to gain unlawful employment, wages, benefits, financial services and credit;

➡️ Payroll Fraud Schemes: Complicit employers may use off-the-books payments, shell companies, unregistered Money Services Business’, check cashing and structured withdrawals to conceal unlawful employment; and

➡️ Red Flag Indicators: FinCEN sets out indicators involving SSN mismatches, recurring check deposits, structured cash withdrawals, peer-to-peer (P2P) payments, limited payroll activity and shell company characteristics.

✅ Firms should review customer due diligence (CDD), transaction monitoring (TM) and SAR escalation controls against the red flags highlighted in the advisory.

 
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