U.S. Customs and Border Protection (CBP) has provided additional information regarding implementation of Executive Order 14411, “Strengthening Customs Enforcement,” signed June 3, 2026.
The Executive Order directs significant changes to the requirements for Importers of Record (IORs), including heightened requirements for foreign IORs.
TLR is a CTPAT-validated customs broker (CVCB) and is preparing for these changes. Foreign IOR clients should begin preparing as well.
What Is Changing for Foreign IORs?
Under Executive Order 14411, foreign IORs making formal entry into the United States will be required to either:
- be validated in CBP’s Customs Trade Partnership Against Terrorism (CTPAT) program, if eligible; or
- use a CTPAT-validated, licensed customs broker (CVCB) to file entries with CBP.
CBP is now providing additional insight into the heightened due diligence CVCBs will be expected to perform when representing foreign IORs.
Expect Additional Vetting and Documentation
CBP has advised that CVCBs will be expected to comprehensively vet foreign IOR clients before conducting customs business on their behalf.
This vetting is expected to include verification and review of information such as:
- legal identity, ownership, beneficial ownership, and business affiliations;
- U.S. assets and ability to pay duties, taxes, fees, and other customs liabilities;
- import and compliance history;
- supply-chain parties and information; and
- product classification, customs valuation, and country of origin.
Brokers will also be expected to maintain records demonstrating that appropriate due diligence was performed.
What Does This Mean for TLR Clients?
As CBP implements these requirements, foreign IORs should expect TLR to request additional corporate, financial, supply-chain, and import compliance documentation.
These requests will be necessary for TLR to satisfy CBP’s heightened due-diligence obligations and continue representing foreign IOR clients.
All Importers Will Need to Maintain “Good Standing”
Executive Order 14411 also directs CBP to establish a “good standing” requirement for all IORs. Good standing will consider an importer’s and its affiliates’ compliance with U.S. customs and trade laws and payment of customs liabilities, among other factors.
Importers that do not maintain good standing may ultimately be prohibited from importing merchandise into the United States or conducting certain import-related activities.
What U.S. Importers Should Know
While the foreign IOR and CVCB requirements discussed above specifically affect foreign Importers of Record, Executive Order 14411 contains additional requirements applicable to all IORs, including U.S. importers.
These include forthcoming good-standing requirements, enhanced vetting, updates to the IOR registry, risk-based compliance measures, and other customs enforcement reforms.
TLR will provide additional guidance as CBP releases implementation details.
What Should Foreign IORs Do Now?
Foreign IOR clients should begin ensuring that their corporate and ownership records, importer information, financial information, supply-chain documentation, product classifications, customs valuations, country-of-origin determinations, and compliance records are current, accurate, and readily available.
TLR will continue monitoring CBP’s implementation of Executive Order 14411 and will communicate additional requirements, documentation requests, and effective dates as they become available.
There is no need to wait for final implementation to prepare. Taking steps now to keep importer and compliance records complete can help reduce potential disruptions as CBP rolls out the new requirements.
Questions About the New Foreign IOR Requirements?
Please contact your TLR representative with questions regarding how these changes may affect your U.S. imports.
This alert is provided for informational purposes and reflects information available as of August 13, 2026. CBP is continuing to develop regulations, policies, guidance, and procedures implementing Executive Order 14411, and requirements may change as additional guidance is issued.
