On June 3, 2026, the White House issued a sweeping Executive Order titled “Strengthening Customs Enforcement,” directing the Department of Homeland Security (DHS) and U.S. Customs and Border Protection (CBP) to implement significant reforms that will materially reshape importer obligations, enforcement standards, and supply chain transparency requirements. While the changes will roll out over the coming months, and the specifics are unknown, the direction is clear: heightened scrutiny, stricter eligibility standards, and reduced flexibility in enforcement outcomes.

Key Reform Area #1: Redefining Importer of Record (IOR) Requirements

Perhaps the most significant component of the Executive Order is the restructuring of Importer of Record (IOR) eligibility and obligations.

Minimum Financial Presence Requirements

CBP is directed to require that all IORs maintain:

• A minimum level of tangible U.S.-based assets, bonding, or both
• Increased bond coverage sufficient to ensure compliance and duty payment

Expanded Disclosure Obligations

IORs will be required to submit enhanced data, including:

• Beneficial ownership information
• Business affiliations
• Domestic asset disclosures
• Anticipated import volumes

Key Reform Area #2: Introduction of a “Good Standing” Requirement

CBP is directed to establish and enforce a “good standing” requirement for all importers.

This standard will be based on:

• Historical compliance with customs laws
• Payment of duties and penalties
• Enforcement and audit history

Importers that fail to meet this standard risk:

• Loss of Import privileges
• Restrictions on appointing brokers or conducting import activities

Key Reform Area #3: Increased Restrictions on Foreign Importers

The Executive Order introduces clear differentiation between U.S. and foreign IORs, imposing stricter requirements on foreign entities.

Key measures include:

• Prohibition on informal entries by foreign IORs
• Heightened bonding and financial requirements
• Enhanced scrutiny of ownership and corporate structure

Key Reform Area #4: Enhanced Enforcement and Penalty Framework

Minimum Penalty Thresholds

The Order directs CBP to establish a minimum penalty floor of 50% of assessed penalties, limiting mitigation flexibility.

Expanded Enforcement Focus

CBP enforcement priorities will include:

• Duty evasion (valuation, classification, origin)
• Transshipment schemes
• Forced labor and prohibited imports
• Misrepresentation of importer identity

Seizure and Disposal Authorities

The Order also enhances CBP’s ability to:

• Seize non-compliant goods
• Streamline abandonment and disposal processes

Key Reform Area #5: Broader Supply Chain Oversight and Transparency

Beyond IOR requirements, the Order directs DHS and CBP to:

• Expand vetting of importers, brokers, and supply chain participants
• Increase data collection and certification requirements
• Improve transparency through public reporting

Implementation Timeline and Next Steps

The Executive Order does not immediately impose new requirements but instead directs DHS and CBP to:

• Develop implementing regulations within 90–180 days
• Propose additional legislative actions to strengthen enforcement authority within the next 90 days.

Implication

While immediate changes may be limited, companies should continue to review their compliance posture and plan appropriately for enforcement measures to increase. Additionally, foreign importers of record should review their compliance structure and domestic assets in anticipation of future clarity on rules.

Tradewin Can Help

If you have known gaps in your compliance program, or you have not invested properly in a risk assessment, transactional audits of your entries, or review of your compliance standing data, it’s never too late to start. There are several mitigation strategies under existing law, including prior disclosures and building up compliance frameworks to prove a reasonable care standard is met, that can be deployed.   We’re here to help.