On June 3, 2026, President Trump issued Executive Order 14411, “Strengthening Customs Enforcement,” directing the Department of Homeland Security and U.S. Customs and Border Protection to revise rules, guidance, and enforcement practices governing both U.S.-based and foreign importers of record, customs brokers, freight forwarders, bonded merchandise custodians, and other participants in the import ecosystem. The order imposes significant compliance and vetting obligations on importers and tightens restrictions on foreign entities operating as importers of record.
What changed
The Executive Order focuses on importer of record (“IOR”) eligibility, foreign IORs, customs bonds, supply-chain disclosures, broker due diligence, penalties, seizure procedures, and enforcement transparency. The Executive Order directs DHS and CBP to revise regulations, policies, and guidance on timelines of 45 days, 90 days, 180 days, and one year.
Importer of Record Eligibility & Good Standing
Within 180 days, CBP must revise IOR eligibility regulations, guidance, and policies to require an IOR to maintain a minimum level of domestic assets and/or bond coverage and increase the minimum required bond coverage for an IOR. IORs must provide additional information, including anticipated import volumes, year organized, ownership disclosures, and any other information CBP considers necessary.
Within 180 days of the date of this order, the Secretary shall require all IORs to maintain “good standing” with CBP, and CBP shall define “good standing” based on the IOR’s and its affiliates’ history of compliance with U.S. customs and trade laws and regulations and payment of required customs liabilities, among other relevant considerations. IORs not in “good standing” with CBP shall not be allowed to import into the United States or otherwise conduct activities directly related to the importation of goods, including designating a customs broker to act as IOR on their behalf.
Foreign Importers of Record
DHS must take steps to prohibit foreign IORs from filing informal entries. For formal entry, a foreign IOR may not rely on a continuous bond to meet the bond requirements for entry, except as permitted by CBP when the foreign IOR has demonstrated that the revenue would be fully protected and that compliance with the laws, regulations, and instructions enforced by CBP would be assured, and must be validated in CBP’s Customs Trade Partnership Against Terrorism (CTPAT), if determined by CBP to be eligible, or use a CTPAT validated and licensed customs broker to file entries with CBP.
Enforcement & Penalties
Actions shall include enforcing liquidated damages claims against bonds for noncompliance; restricting in-bond utilization; increasing audits; and imposing maximum penalties for brokers who, for example, fail to conduct due diligence, repeatedly represent noncompliant clients, or fail to cooperate in a timely manner with requests for information by CBP.
CBP will establish a minimum penalty floor of not less than 50 percent of the assessed penalty, absent exceptional circumstances that materially impact national security. Mitigation for repeat offenders will be eliminated.
Registry & Risk Classification
Within the next 180 days, DHS is expected to reorganize the IOR registry and create risk-based tiers to classify IORs based on previous compliance history, audits, and other factors.
Why it matters
The Executive Order signals that the administration wants CBP to make it harder for noncompliant or hard-to-reach importers to enter goods into the United States without meaningful financial responsibility, documentation, or enforcement exposure.
For practitioners advising clients on import operations, the practical stakes are high:
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Bonding & Asset Requirements: CBP must require each IOR to maintain a minimum level of tangible domestic assets, bonding, or both, in an amount CBP determines is necessary to ensure compliance with U.S. customs and trade laws. CBP must also increase minimum required bond coverage. Established U.S. companies face elevated disclosure and bonding costs; foreign importers, startups, and thinly capitalized entities face the most significant barriers.
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Good Standing as a Market-Access Prerequisite: CBP’s potential incoming formal risk-ranking system means importers should address prior penalties, unpaid duties, unresolved audits, weak documentation, affiliate compliance issues, or repeat violations to avoid future compliance scrutiny.
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Foreign Importer Restrictions: The Executive Order places heightened scrutiny on foreign IORs. DHS must take steps to prohibit foreign IORs from filing informal entries. Foreign suppliers acting as importers will need CTPAT validation or a validated customs broker to continue formal-entry operations.
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Penalty & Audit Escalation: CBP will enforce liquidated damages claims against bonds for noncompliance, restrict in-bond utilization, and increase audits. Penalty mitigation for repeat offenders disappears.
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Timeline & Urgency: The structural IOR reforms (asset requirements, good standing, enhanced vetting, registry overhaul) follow at 180 days, by November 30, 2026. Companies have roughly five months to align operations before the new requirements take effect.
Way forward
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Review your IOR structure now. If you counsel foreign entities, U.S.-based affiliates, or joint-venture importers, assess whether current domestic-asset and bonding positions will survive the new minimums. Model scenarios for elevated bond costs and asset requirements.
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Audit compliance history and affiliate records. Identify any prior CBP penalties, unpaid duties, unresolved audits, or enforcement actions that could affect “good standing” status. Prepare a remediation plan (e.g., prior disclosures, voluntary liquidation of liabilities) before November 2026.
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Upgrade customs-broker vetting. Confirm that your client’s customs broker holds CTPAT validation and a clean compliance history. The order imposes stricter accountability on brokers; using an unvalidated or noncompliant broker now exposes your client to heightened liability.
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Prepare supply-chain certifications and documentation. Importers will need to certify compliance with the Countering America’s Adversaries through Sanctions Act and related provisions, and provide detailed information about imported goods’ supply chains and production methods, including manufacturer product identifiers and key specifications like composition, grade, or size.
Disclaimer
This article summarizes a federal executive order and is not legal advice. We are a software company, not a law firm, and nothing herein constitutes legal counsel or a substitute for consultation with a licensed attorney. Always verify the current text of the executive order and any implementing regulations, guidance, or policy updates against the primary source and consult a qualified customs or trade attorney before making business decisions. Agency policy and regulatory timelines can change without notice.