President Trump’s Executive Order 14411, “Strengthening Customs Enforcement,” signed June 3, 2026, represents a significant shift in how the Administration wants CBP to manage importers, customs brokers, and import compliance generally.

The underlying message is straightforward: CBP should know exactly who is importing, have greater assurance that duties and penalties can be collected, demand more information about imported goods and their supply chains, and impose substantially tougher consequences for noncompliance.

Here are the major provisions:

  • Much greater scrutiny of Importers of Record. Within 180 days, DHS is directed to revise IOR eligibility requirements. Importers may be required to maintain a minimum level of U.S. tangible assets, increased bonding, or both. CBP is also directed to collect significantly more information, including anticipated import volumes, ownership and beneficial ownership, business affiliations, year organized, and domestic assets.
  • A new “good standing” requirement. CBP must establish standards for determining whether an importer is in good standing based on its compliance history, payment of customs liabilities, and the history of affiliated companies, among other factors. An importer that loses good-standing status could effectively lose the ability to import into the United States.
  • Ongoing vetting. CBP is directed to establish enhanced and recurrent vetting not only for importers, but also for foreign IORs, IOR affiliates, customs brokers, bonded-facility custodians, and freight forwarders.
  • The IOR registry gets cleaned up and risk rated. CBP must remove inactive IORs, confirm that active importers comply with applicable requirements, and establish risk-based tiers based on compliance history, enforcement actions, audits, and other factors.
  • Foreign IORs face significantly tougher requirements. Foreign IORs are to be prohibited from making informal entries. For formal entries, they generally will not be able to rely on continuous bonds unless CBP determines revenue and compliance are adequately protected. They may also have to be CTPAT validated or use a CTPAT-validated, licensed customs broker. The EO also defines a U.S. IOR in a way intended to prevent foreign companies from using shell entities or nominal U.S. operations to qualify as domestic importers.
  • More supply-chain and product information will be required. DHS is directed to establish heightened disclosure and certification requirements. These may include foreign tax and global business identifiers, supply-chain and production information, manufacturer product identifiers such as model/style numbers, specifications such as composition, grade or size, and certifications relating to certain supply-chain compliance requirements.
  • Foreign export documentation could become part of U.S. entry compliance. The EO directs DHS to establish a requirement that importers provide documentation or information that the foreign exporter was required to submit to its own country’s customs authority before exporting to the United States. This could give CBP another means of comparing what was declared abroad with what is declared upon U.S. importation.
  • Enforcement is explicitly being increased. The order calls for more audits, greater enforcement of liquidated damages against bonds, possible restrictions on in-bond privileges, and stronger enforcement against forced labor, misclassification, undervaluation, and illegal transshipment, including EAPA investigations.
  • Customs brokers are in the crosshairs. The EO directs CBP to impose maximum penalties on brokers that fail to conduct appropriate due diligence, repeatedly represent noncompliant clients, or fail to cooperate promptly with CBP requests. This makes broker customer vetting and documented due diligence considerably more important.
  • Penalty mitigation becomes much less forgiving. DHS is directed to revise mitigation standards to establish a minimum penalty floor of at least 50% of the assessed penalty, absent exceptional circumstances materially affecting national security; establish minimum liquidated-damages floors; and eliminate mitigation for repeat offenders.
  • CBP is being told to dispose of noncompliant goods faster. The EO directs DHS to streamline seizure and disposal, make voluntary abandonment easier, increase bonding requirements for high-risk shipments, and potentially use third parties for disposal.
What it really means for importers:

This is more than an enforcement initiative aimed at catching bad actors. It points toward a different compliance model in which CBP continuously evaluates whether an importer should be permitted to import at all.

Historically, an importer obtained an IOR number, maintained a bond, filed entries, and was subject to CBP enforcement when problems arose. Under the framework contemplated by EO 14411, CBP would have considerably more information about the importer, its owners, affiliates, assets, compliance history, and supply chain, and would continually reassess its risk.

It also makes the consequences of mistakes potentially much greater. Importer identity, valuation, classification, origin, forced-labor compliance, transshipment, supply-chain (tracing) documentation, and duty payment are all clearly enforcement priorities.

And we’re already seeing the first implementation step. As we shared in our August 19 flash, CBP announced that, beginning September 18, 2026, it will enhance enforcement of the accuracy of information contained on CBP Form 5106. Inaccurate information can result in the immediate voiding of an IOR number. CBP expressly describes this as an initial step in implementing EO 14411, meaning considerably more rulemaking, guidance and enforcement changes are still coming.

This is certainly a developing story that you need to follow. As always, we will continue to monitor developments and provide updates as further information becomes available.