Executive Order 14406 is fundamentally about identity verification, not automatically checking every banking
customer’s immigration status. Financial institutions must first verify customers’ identities and beneficial ownership,
then assess whether additional immigration or employment authorization information is warranted by specific risk
indicators. A new article compares this approach to Form I-9 requirements, emphasizing document authentication,
biometric verification, liveness detection, and risk-based processes. It concludes that identity verification should
precede any immigration-status assessment.

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