No, we are not aware of any requirement that financial institutions employ only U.S. citizens. You are permitted and required to make employment decisions on the basis of whether an individual is authorized to work in the United States. However, authorization to work does not require U.S. citizenship. In fact, both federal and Illinois law prohibit discrimination on the basis of an individual’s citizenship status, provided that the individual is legally authorized to work in the United States.

For resources related to our guidance, please see:

• Federal law, 8 USC 1324b(a)(1) (prohibition of discrimination based on citizenship status for employers with more than four employees)

• Illinois Human Rights Act, 775 ILCS 5/2-102(A) (prohibition of discrimination based on citizenship status for employers with more than fifteen employees)

• Illinois Human Rights Act, 775 ILCS 5/2-101(K) (“citizenship status” means an individual’s status as a born U.S. citizen, naturalized U.S. citizen, U.S. national, or a non-U.S. citizen that is not an unauthorized alien).