On June 3, 2026, President Trump signed an executive order titled “Strengthening Customs Enforcement,” directing Customs and Border Protection (CBP) and the Department of Homeland Security (DHS) to pursue legislative, regulatory and enforcement initiatives aimed at strengthening import compliance and increasing accountability throughout the import process.
The executive order signals a significant shift toward increased importer vetting, enhanced enforcement measures, stricter bonding requirements and greater supply chain transparency. If implemented, the changes would represent one of the most substantial expansions of customs enforcement authorities in recent years.
The executive order directs DHS and CBP to evaluate measures that would strengthen importer of record (IOR) requirements by establishing minimum asset thresholds, increasing bond coverage and requiring additional disclosures regarding ownership, business affiliations, import activity and anticipated import volumes.
The administration is also seeking to distinguish foreign IORs from domestic importers by imposing additional restrictions and qualification requirements. Potential changes include limiting the use of informal entries by foreign IORs, requiring enhanced bonding and establishing participation requirements in programs such as the Customs-Trade Partnership Against Terrorism (CTPAT) where applicable.
CBP has been directed to develop a “good standing” registry for importers of record. Under the proposal, importers that fail to meet compliance standards could face restrictions on conducting import activity, including limitations on their ability to designate customs brokers to transact customs business on their behalf.
The enforcement provisions are equally significant. CBP has been instructed to increase audits, strengthen bond enforcement, enhance scrutiny of in-bond movements, establish minimum penalty amounts and revise mitigation guidelines. The executive order also calls for increased enforcement against undervaluation, tariff evasion, misclassification, transshipment schemes and violations of forced labor laws. Customs brokers may also face increased scrutiny when representing importers that fail to comply with the new requirements.
The executive order establishes an aggressive implementation timeline:
- Within 45 days, DHS must submit recommendations to the president and Congress regarding legislative changes necessary to achieve the administration’s objectives.
- Within 90 days, CBP must revise mitigation guidelines, establish minimum penalty frameworks, and implement new disclosure and certification requirements.
- Within 180 days, CBP must publish proposed regulations for public comment that address importer vetting procedures, bonding requirements, ownership and asset disclosures, foreign IOR restrictions, CTPAT-related requirements, and the establishment of the “good standing” eligibility standards.
While these measures are not yet in effect, importers should closely monitor both legislative developments and future CBP rulemaking. Businesses that regularly import goods into the United States may wish to engage with industry associations, trade organizations, customs counsel and elected representatives during the legislative and public comment process. Participation at these stages will provide importers with the best opportunity to influence future requirements and help ensure that any new regulations reflect practical business realities while maintaining effective enforcement objectives.
