Since January 2026, President Donald Trump and his Administration have made several significant announcements detailing the administration’s fraud enforcement agenda.
Most recently, on Monday, March 16, 2026, President Trump signed an Executive Order (EO), “Establishing the Task Force to Eliminate Fraud,” focused on benefits fraud within “Federal benefit programs, including programs administered jointly with State, local, tribal, and territorial partners.” This EO creates a task force chaired by Vice President JD Vance, with Federal Trade Commission (FTC) Chairman Andrew Ferguson serving as the Vice Chairman of the Task Force, and consists of representatives from nearly a dozen federal agencies.
According to the EO, “some States have embraced loopholes that avoid individual eligibility validation, allow self-certification of eligibility, and expand eligibility,” and those states have “refused to institute basic fraud controls” for welfare benefits. The priorities of the Task Force include coordinating a national strategy to stop fraud, waste, and abuse within federal benefits programs (housing, food, medical care, and cash assistance), including maximizing enforcement of eligibility requirements; potentially pausing funding “until controls can be established”; and promoting sharing information “between State, local, tribal, and territorial governments and the Federal Government.” The Task Force’s mandate aligns with recent Centers for Medicare & Medicaid Services’ (CMS) actions, including CMS’s February 25 deferral of $259.5 million in Minnesota Medicaid funds, and its nationwide temporary moratorium on enrollment of Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) companies.
The March 16 EO follows earlier orders and announcements about the Administration’s anti-fraud objectives. Of note, on March 6, President Trump issued an EO, “Combatting Cybercrime, Fraud, and Predatory Schemes Against American Citizens.” The March 6 EO focused on fraud and cybercrimes by Transnational Criminal Organizations (TCOs), and specifically noted that the “Attorney General shall continue to prioritize prosecutions of defendants engaged in cyber-enabled fraud, including scam centers and sextortion schemes” (fraud typologies significantly affecting financial institutions). The March 6 EO also directed the Attorney General to submit a recommendation for a Victims’ Restoration Fund for compensating victims of cyber-enabled fraud schemes from funds from the TCOs. The March 6 EO further directs the Secretary of State to impose consequences on foreign governments that tolerate cyber-enabled fraud (including, but not limited to, the application of targeted sanctions, visa restrictions, and trade penalties). For additional background on the March 6 EO and the Administration’s broader cyber strategy, see our Legal Update, Trump Administration Releases Cyber Strategy for America and Related Executive Order on Combatting Cybercrime.
These two EOs follow last month’s release of the Department of Justice Criminal Division Fraud Section Year in Review for 2025, which came on the heels of the White House’s January 8, 2026, announcement of the Department of Justice’s Division for National Fraud Enforcement, a new DOJ division intended to centralize and elevate the federal government’s approach to fraud enforcement. The following day, the Treasury Secretary announced a set of related Treasury-led initiatives focused on alleged government benefits fraud in Minnesota, including actions by the Financial Crimes Enforcement Network and the Internal Revenue Service. As discussed in our Legal Update, DOJ Highlights 2025 Fraud Enforcement Activity as New DOJ Division for National Fraud Enforcement Announced, these developments reflect the Administration’s focus on centralizing and intensifying fraud enforcement across the federal government. This was further demonstrated by DOJ’s announcement of its first-ever department-wide Corporate Enforcement Policy for all criminal matters (explained further in our Legal Update, DOJ Releases First-Ever Department-Wide Corporate Enforcement Policy For All Criminal Matters).
Takeaways for Banks and Other Financial Institutions
The Treasury-led initiatives announced in January 2026—including actions by FinCEN and the IRS—signal that the federal government views financial institutions as both key partners in combating fraud and potential fraud enforcement targets. Banks and other financial institutions face heightened expectations around suspicious activity reporting, particularly for transactions implicating federal benefit programs.
As we discussed in our earlier Legal Update on the Administration’s cyber strategy, the March 6 EO on cybercrime compounds the compliance risks. The proposed Victims’ Restoration Fund—which would compensate victims of cyber-enabled fraud from TCO-linked assets—could increase pressure on financial institutions to identify and freeze connected funds. Banks and other institutions holding or processing assets with a potential nexus to TCO activity should evaluate whether their existing asset-tracing and freeze protocols are sufficient to respond to the government requests and legal process that may follow from the Fund’s implementation.
Separately, the March 6 EO’s directive that the Secretary of State impose consequences on foreign governments that tolerate cyber-enabled fraud—including targeted sanctions, visa restrictions, and trade penalties—may have significant downstream effects for financial institutions. New sanctions designations or restrictions could require institutions to update their screening systems, reassess correspondent banking relationships, and enhance due diligence on transactions involving jurisdictions identified as tolerating cyber-enabled fraud. Financial institutions should monitor developments in this area closely, and ensure their compliance infrastructure can adapt quickly to any new designations or restrictions that emerge.
In addition, the March 6 EO provides banks and other financial institutions with the opportunity to engage with the Administration on addressing increasingly prevalent fraud scams targeting bank customers, particularly “spoofing,” phishing, “pig butchering,” and romance schemes, which result in customers unwittingly authorizing the transfer of funds to persons who have fraudulently misrepresented their identities.
More broadly, financial institutions should review their cybersecurity frameworks, transaction monitoring systems, and customer due diligence procedures in light of these enforcement priorities.
Visit us at mayerbrown.com
Mayer Brown is a global services provider comprising associated legal practices that are separate entities, including Mayer Brown LLP (Illinois, USA), Mayer Brown International LLP (England & Wales), Mayer Brown (a Hong Kong partnership) and Tauil & Chequer Advogados (a Brazilian law partnership) and non-legal service providers, which provide consultancy services (collectively, the "Mayer Brown Practices"). The Mayer Brown Practices are established in various jurisdictions and may be a legal person or a partnership. PK Wong & Nair LLC ("PKWN") is the constituent Singapore law practice of our licensed joint law venture in Singapore, Mayer Brown PK Wong & Nair Pte. Ltd. Details of the individual Mayer Brown Practices and PKWN can be found in the Legal Notices section of our website. "Mayer Brown" and the Mayer Brown logo are the trademarks of Mayer Brown.
© Copyright 2026. The Mayer Brown Practices. All rights reserved.
This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
[View Source]
