EXECUTIVE ORDER STRENGTHENS CUSTOMS ENFORCEMENT AND INCREASES REQUIREMENTS FOR IMPORTERS OF RECORD
October 22, 2026
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On June 3, 2026, President Trump issued Executive Order 14411, directing the Department of Homeland Security and U.S. Customs and Border Protection (“CBP”) to strengthen customs enforcement and increase oversight of importers of record (“IORs”). The order focuses on ensuring that IORs are properly identified, financially accountable for customs duties, and compliant with U.S. customs and trade laws.
Among other measures, the order directs CBP to increase minimum bond requirements and require IORs to maintain sufficient domestic assets, bonding, or both. IORs will also be required to provide additional information to CBP, including anticipated import volumes, ownership and beneficial ownership information, business affiliations, and domestic assets. CBP will also establish “good standing” requirements and conduct enhanced, recurring vetting of IORs and other parties involved in importing goods.
The order places additional requirements on foreign IORs, which will be prohibited from using informal entry procedures and, for formal entries, generally will not be permitted to rely on continuous bonds unless CBP determines that customs revenue will be protected and compliance requirements will be met. Certain foreign IORs will also be required to participate in the Customs-Trade Partnership Against Terrorism (“CTPAT”) program or use a CTPAT-validated and licensed customs broker.
Finally, the order directs CBP to strengthen import disclosure and certification requirements and increase enforcement of customs penalties, with particular attention to forced labor, misclassification, undervaluation, and illegal transshipment. It also establishes a minimum penalty of 50 percent of the assessed penalty, absent exceptional circumstances.
This Aviation Regulatory Update is intended to keep readers current on developments in the law. It is not intended to be legal advice. If you have any questions or require additional information, please contact Evelyn D. Sahr at 202.659.6622 or esahr@eckertseamans.com; Drew M. Derco at 202.659.6665 or dderco@eckertseamans.com; Xander B. Silva at 412.566.6069 or xsilva@eckertseamans.com, Tyler R. Myers at 202.659.6642 or trmyers@eckertseamans.com; or any other attorney at Eckert Seamans with whom you have been working.
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