There are recent reports that the Trump administration is considering an executive order or Treasury action requiring banks to collect customers’ citizenship information. This could include collecting documents such as passports for existing customers, not just new account holders. That is not “tightening the rules.” It is a sweeping expansion of federal data collection that will raise costs for banks and customers, shrink access to basic banking services and push more activity into the shadows.

The intention may be to address illegal immigration and tighten enforcement, but this approach treats banks like a substitute for a functioning immigration system. Washington’s struggle to consistently enforce immigration policy does not justify shifting the burden onto financial institutions and law-abiding Americans. Expanding government reach into private financial relationships is not a solution to immigration failures. Fixing immigration policy is. Offloading enforcement costs to banks is just another way politicians shift the blame and hide the price tag.

Banks already operate under serious identity verification mandates. Federal Customer Identification Program requirements under 31 CFR 1020.220 require banks to collect identifying information and use risk-based procedures to verify identity so they can form a “reasonable belief” that they know the customer’s true identity. Identity verification is already the law. This proposal adds a new, separate layer: citizenship classification at scale.

That means unforeseen costs imposed on people who are already complying with the law. Banks will need new systems, new staff training, new vendors, new audits and new exception-handling processes for customers who cannot meet the new demands immediately. Compliance costs do not stay at the bank. They show up in higher fees, fewer low-cost accounts and worse service.

It also means more friction just to participate in the modern economy. A “citizenship information” mandate would make it harder for people to open accounts and could impose extensive new documentation obligations on existing customers. Put simply, this is a regulatory landmine. When regulators increase penalties for getting it wrong, banks are forced to become more conservative about whom they can serve and to do so at a higher cost.

That is how debanking gets worse. President Trump’s executive order — Guaranteeing Fair Banking for All Americans — sought to address the root cause of this very issue by pushing back on the governmental regulatory overreach that has driven account closures at financial institutions across the country. A new nationwide citizenship-data mandate would only turbocharge the same dynamics that force banks to close accounts rather than risk running afoul of compliance errors.

Now, the privacy problem. This proposal would require financial institutions to collect and transmit large amounts of highly sensitive personal information. The larger the dataset, the bigger the target. More collection and more transmission create more points of failure along with a greater risk of breach, internal misuse, and mission creep. Once the federal government builds the pipeline, it will not be limited to the original justification.

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Conservatives have pushed back for years against government intrusion into personal financial matters, including mandates that compel private disclosure to the government. The battle over beneficial ownership reporting under the Corporate Transparency Act is a recent example of how quickly “anti-crime” justifications turn into broad surveillance architecture. Requiring banks to collect citizenship information on hundreds of millions of customers would be an even broader expansion of federal data collection than what small businesses were told to accept. 

And the burden will not be evenly distributed. Many Americans do not have passports or easy access to formal documentation. The Washington Post reports that roughly half the population lacks a passport, and banking industry experts warn that the requirement could restrict access to financial services and push people toward higher-cost options. Seniors, rural residents and lower-income individuals are the most likely to get caught in the gears. For rural communities, the challenge is worse because documentation offices and support services are farther away and harder to reach. 

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That leads to the most self-defeating outcome of all: forcing people out of traditional banking. When compliance barriers rise, people do not stop earning, spending, and saving. They route around the system. That means more cash-heavy activity and more informal transactions, making financial crime harder to detect and reducing transparency. This is why heavy-handed financial mandates often backfire. They can drive legitimate activity away from institutions where patterns can be monitored and toward channels where law enforcement sees less, not more.

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This is not an argument for weak enforcement of existing law. It is an argument for doing enforcement the right way, using targeted tools aimed at bad actors, not building an ever-expanding registry through the banking system that sweeps up everyone else. Banks exist to safeguard deposits and allocate capital, not to become a nationwide citizenship checkpoint.

If Washington wants a more secure and lawful system, it should start with policies that increase compliance where it matters and reduce compliance burdens where it does not. This proposal does the opposite: it punishes the compliant, expands government reach, and makes the system less transparent by pushing people away from it.

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