How are you handling the May 19 Executive Order on ITIN for your non-resident foreign national clients?

The EO "Restoring Integrity to America's Financial System" flags ITIN use for account opening and credit products as a potential risk factor — specifically where the applicant "lacks verified lawful immigration status."

I'm curious how this is playing out in your practice, particularly for non-resident aliens from countries like Germany who hold a valid passport, enter on ESTA or B-1/B-2, and use an ITIN purely for US tax compliance — no SSN, no permanent immigration status.

A few questions:

Does the "lawful immigration status" carve-out in the EO realistically protect ESTA/B-visa holders in practice, or are you seeing banks apply enhanced due diligence indiscriminately — both for personal accounts and business banking?
Has your workflow around ITIN applications (W-7) or account opening recommendations changed since May 19?
Are there specific banks or account types you're now steering foreign nationals toward — or away from — for personal or business use?
For clients building US credit history via ITIN (authorized user pathway, secured cards etc.) — do you see this becoming more restricted or effectively unchanged?
Anything you're advising clients to do proactively before the Treasury advisory (due ~July 2026) and the BSA rule changes land?

Would love to hear how you're navigating this.

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How are you handling the May 19 Executive Order on ITIN for your non-resident foreign national clients?