Executive Order on Strengthening Customs Enforcement

On June 3, 2026, President Trump signed an Executive Order titled "Strengthening Customs Enforcement." The Order directs the Department of Homeland Security (DHS) and U.S. Customs and Border Protection (CBP) to review and revise various customs enforcement programs, importer requirements, bonding standards, and compliance procedures.

The Executive Order does not establish new tariff rates. Instead, it focuses on strengthening customs compliance, increasing oversight of Importers of Record (IORs), enhancing supply chain transparency, and expanding enforcement tools available to CBP.

Many of the provisions outlined in the Executive Order will require additional rulemaking, agency action, or implementation guidance before taking effect.

Key Areas of Focus

• 1. Enhanced Importer of Record Requirements

  CBP has been directed to review Importer of Record eligibility requirements and consider additional standards related to financial responsibility and importer verification.

  Potential requirements under review include:

  • Increased bond coverage requirements

  • Verification of U.S. business presence and assets

  • Additional ownership and beneficial ownership disclosures

  • Business affiliation information

  • Anticipated import activity and transaction volumes

  • Other information deemed necessary by CBP

  These changes indicate CBP may move toward more robust importer verification and vetting requirements.

• 2. Additional Requirements for Foreign Importers of Record

  The Executive Order draws a sharp line between U.S. Importers of Record and foreign Importers of Record.

  Foreign IORs are expected to face heightened requirements, especially in two areas: 

  • Informal entries:

    • Foreign IORs are to be prohibited from filing informal entries. 

  • Formal entries:

    • Foreign IORs may face restrictions on the use of continuous bonds.

    • CBP may require a determination that revenue is adequately protected before allowing the use of a continuous bond.

    • CBP may also require evidence that the importer meets specified compliance standards.

  • Additional compliance requirements:

    • Foreign IORs may be required to participate in the Customs Trade Partnership Against Terrorism (CTPAT) program.

    • Alternatively, they may be required to use a licensed customs broker that has been validated through the CTPAT program.

    • Additional importer verification or vetting requirements may also be implemented through future CBP guidance.

  This is one of the most important pieces of the Order. Foreign sellers, non-resident importers, e-commerce sellers, Delivered Duty Paid (DDP) sellers, and companies using foreign IOR structures should review their import model now. 

• 3. Importer "Good Standing" Standards

  CBP has been directed to establish a "good standing" framework for Importers of Record.

  Factors may include:

  • Customs compliance history

  • Timely payment of duties, taxes, and fees

  • Prior enforcement actions

  • Compliance history of affiliated entities

  Importers that do not meet established standards could face additional restrictions or enhanced oversight.

• 4. Risk-Based Importer Monitoring

  The Executive Order directs CBP to modernize its Importer of Record registry by:

  • Removing inactive importers

  • Verifying active importer information

  • Implementing risk-based monitoring and compliance assessments

  This initiative may result in increased importer profiling and compliance-based oversight.

• 5. Expanded Supply Chain Disclosure Requirements

  CBP has been directed to evaluate enhanced reporting and certification requirements related to supply chain compliance.

  Potential information requests may include:

  • Manufacturer identification information

  • Product specifications and composition data

  • Foreign tax or business identifiers

  • Global business identification numbers

  • Supply chain certifications

  • Export documentation maintained by foreign suppliers

  Importers may need to work more closely with suppliers to ensure supporting documentation is available when requested.

• 6. Increased Enforcement and Penalty Measures

  The Executive Order directs CBP to review current penalty mitigation policies and enforcement procedures.

  Areas identified include:

  • Minimum penalty mitigation thresholds

  • Increased liquidated damages enforcement

  • Enhanced bond claim collection efforts

  • Expanded audit activity

  • Additional scrutiny of in-bond movements

  • Stronger enforcement actions for repeat violations

  Importers should anticipate continued emphasis on compliance, recordkeeping, and duty accuracy.

• 7. Broker and Supply Chain Partner Oversight

  The Order also directs increased oversight of:

  • Licensed customs brokers

  • Freight forwarders

  • Bonded warehouse operators

  • Other parties involved in customs transactions

  Customs brokers may be expected to enhance client due diligence procedures and maintain additional documentation supporting importer onboarding and compliance reviews.

  This could especially affect foreign IORs, high-risk commodities, forced labor risk, undervaluation concerns, transshipment risk, and importers with frequent post-entry issues. 

• 8. Seizure and Disposition of Non-Compliant Goods

  CBP has been directed to streamline procedures related to:

  • Seizure of non-compliant merchandise

  • Voluntary abandonment processes

  • Disposal of detained or seized goods

  The goal is to improve enforcement efficiency and reduce delays in resolving non-compliant shipments.

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Regulatory Context

The Executive Order aligns with several ongoing customs enforcement priorities that have received increased attention in recent years, including:

• Importer Accountability

  • CBP has continued to focus on ensuring that Importers of Record maintain adequate financial responsibility, provide accurate entry information, and remain available to satisfy customs obligations when necessary.

• Supply Chain Transparency

  • Recent enforcement initiatives have placed greater emphasis on supply chain visibility, importer recordkeeping, and documentation supporting origin, valuation, classification, and sourcing claims.

• E-Commerce and Low-Value Shipments

  • Federal agencies have increased their review of high-volume, low-value import programs and simplified entry procedures, particularly where compliance oversight and duty collection may present challenges.

• Duty Collection and Trade Compliance

  • CBP continues to prioritize enforcement efforts related to undervaluation, misclassification, transshipment, and other practices that may impact the assessment and collection of duties, taxes, and fees.

• Forced Labor and Supply Chain Compliance

  • The Executive Order also reflects ongoing enforcement efforts related to forced labor restrictions, sanctions compliance, and other supply chain due diligence requirements.

• Future Regulatory Activity

  • The Executive Order directs federal agencies to evaluate additional regulatory and legislative recommendations. As a result, importers should continue monitoring future CBP guidance, rulemaking activity, and implementation measures that may affect importer eligibility, bonding, and compliance obligations.

Potential Impact Areas

Organizations that may be most affected include:

• Foreign Importers of Record

• Non-resident importers

• DDP sellers

• E-commerce sellers

• Marketplace sellers

• Importers utilizing informal entry programs

• Importers with high-volume, low-value shipments

• Importers with weak supplier documentation

• Importers in high-duty environments

• Importers subject to AD/CVD, Section 232, Section 301, forced labor, or sanctions risks

• Customs brokers handling foreign IORs or high-risk clients

• Freight forwarders and bonded warehouse operators

Recommended Next Steps

Importers should consider reviewing:

1. Current Importer of Record structures and responsibilities

2. Foreign or non-resident importer arrangements

3. Bond sufficiency and financial exposure

4. Beneficial ownership and business documentation

5. Supplier documentation and product records

6. Supply chain traceability procedures

7. High-risk commodities and sourcing locations

8. Broker and service provider compliance processes

9. Prepare for more CBP audits, CF-28s, penalty cases, and bond claims

10. Watch for CBP guidance, Federal Register notices, Cargo Systems Messaging Service (CSMS) messages, and implementation guidance

What This Means for Customs Brokers

The Executive Order places increased emphasis on customs broker oversight and due diligence responsibilities.

The Order directs CBP to evaluate enforcement measures for brokers that fail to conduct appropriate due diligence, repeatedly represent non-compliant importers, or fail to respond timely to CBP requests for information.

As CBP develops implementation guidance, customs brokers may wish to review and strengthen internal compliance procedures, including:

• Client onboarding and verification processes

• Foreign Importer of Record (IOR) review procedures

• Bond sufficiency monitoring and escalation protocols

• Documentation and resolution of potential compliance concerns

• Recordkeeping and audit preparedness

• Internal escalation procedures for higher-risk accounts

• Processes for responding to CBP inquiries and requests

• Written communications outlining importer responsibilities and compliance obligations

While additional guidance is expected, brokers should anticipate increased scrutiny of importer due diligence practices and compliance controls.

Bottom Line

The Executive Order represents a significant customs enforcement initiative focused on importer accountability, supply chain transparency, bonding adequacy, and compliance oversight.

While many provisions will require additional rulemaking before implementation, importers, customs brokers, and supply chain participants should expect increased documentation requirements, enhanced compliance reviews, and expanded enforcement activity as CBP develops and implements these directives.