Executive Order to Overhaul U.S. Customs Enforcement

On June 3, 2026, President Trump issued a comprehensive Executive Order (EO) titled “Strengthening Customs Enforcement.” This directive initiates an aggressive, fast-tracked overhaul of U.S. trade enforcement designed to eliminate import loopholes, eradicate duty evasion, and drastically increase accountability for all Importers of Record (IORs).

The EO heavily targets foreign entities and low-value imports, significantly raises financial entry barriers, and severely restricts the government’s ability to lower or mitigate fines for noncompliance.

Key Takeaways for Importers

Aggressive Restrictions on Foreign IORs: Foreign importers face immediate operational hurdles. They are now entirely banned from utilizing informal entry processes (low-value shipments). For formal entries, foreign IORs are blocked from using continuous bonds (unless granted a rare exception) and must either achieve CTPAT validation or utilize a CTPAT-validated U.S. customs broker.
New Financial and Disclosure Barriers: Within 180 days, all IORs must maintain heightened minimum bond coverages, prove minimum levels of tangible domestic assets, and disclose highly granular corporate data to CBP—including beneficial ownership and business affiliations.
Mandatory “Good Standing” Status: CBP will establish strict “good standing” criteria based on compliance history. Importers falling out of good standing—such as those linked to illicit substances or repeat trade violations—will face an immediate, total ban on importing privileges.
Supply Chain Transparency & Foreign Parity: Within 90 days, foreign exporters must provide CBP with the exact same documentation they submitted to their local customs administration prior to export. Importers will also be forced to disclose deep supply chain details, including specific manufacturing product identifiers and production specifications.
Severe Penalty Floors & Elimination of Discretion: The EO sharply curtails CBP’s ability to lower fines. A mandatory minimum penalty floor of 50% of the originally assessed amount is being established, and fine mitigation is completely eliminated for repeat offenders.
Heightened Customs Broker Liability: Customs brokers face maximum penalties and intense scrutiny if they fail to conduct rigid due diligence or repeatedly represent noncompliant clients.

Implementation & Outreach Timeline

The White House has established strict, tiered windows for agency rulemaking, legislative outreach, and final performance reporting:

Phase 1: Immediate & Prompt Mandates

Action Context: The Secretary of Homeland Security must promptly issue, amend, modify, or rescind regulations to enact the formal entry CTPAT requirements, the continuous bond ban for foreign IORs, and the total ban on foreign informal entries.

Phase 2: The 45-Day Window

Deadline: July 18, 2026
Legislative Outreach: The Secretary of Homeland Security, in direct consultation with the Director of the Office of Management and Budget (OMB), must submit formal recommendations for new trade legislation to the President through the Senior Counselor for Trade and Manufacturing.

Phase 3: The 90-Day Window

Deadline: September 1, 2026
Mitigation Restrictions: Revision of all mitigation standards to implement the mandatory 50% penalty floor and eliminate mitigation options for repeat offenders.
Foreign Pre-Export Matching: Rollout of requirements forcing foreign exporters to submit their local customs documentation to CBP prior to U.S. importation.
Streamlined Cargo Seizures: Implementation of expedited cargo disposal, third-party destruction protocols, and a reduction in regulatory burdens for voluntary cargo abandonment.
Transparency Infrastructure: Steps taken to require expiration dates on trade confidentiality requests and outline annual enforcement transparency reports.

Phase 4: The 180-Day Window

Deadline: November 30, 2026
IOR Eligibility Overhaul: Revision of financial regulations forcing IORs to disclose beneficial ownership, business affiliations, and domestic asset values while updating minimum bond coverage amounts.
“Good Standing” Launch: Activation of the compliance-based registry standard to ban non-compliant or illicit substance-linked importers.
Registry Tiering & Purge: Elimination of inactive IOR accounts and organization of remaining entities into risk-based compliance tiers.
Enhanced Vetting Infrastructure: Implementation of continuous, recurrent vetting procedures for foreign IORs, customs brokers, bonded warehouse custodians, and freight forwarders.

Phase 5: The 1-Year Performance Assessment

Deadline: June 3, 2027
Executive Assessment: The Secretary of Homeland Security must deliver a comprehensive report evaluating the realized effectiveness of these customs measures to the President via the U.S. Trade Representative (USTR), the Assistant to the President for Economic Policy, and the Senior Counselor for Trade and Manufacturing.

The full EO may be found here.

The Strengthening Customs Enforcement Fact Sheet may be found here.

JSC Compliance will continue to monitor and distribute updates when they become available. If you have any questions, please contact our JSC Compliance team.