Executive Order 14411, “Strengthening Customs Enforcement,” was signed on 3 June 2026 and published at 91 FR 35125. It does not change a duty rate. It changes who is allowed to bring goods into the United States — and what CBP can demand of them before, during and after an entry.

If you import full containers and your Importer of Record is a company you don’t control, this order matters to you more than any tariff headline.

What the order actually requires

Everything below is from the text of the order itself.

1. Higher eligibility bar for every IOR — Sec. 2(a)

CBP is directed to revise importer eligibility rules so that an IOR must:

  • maintain, at all times, a minimum level of tangible domestic assets, bonding, or both, as CBP determines necessary
  • carry increased minimum bond coverage
  • submit additional data and identification, including:

– anticipated import volumes

– year organised

– ownership and beneficial ownership disclosures

– business affiliation disclosures

– domestic asset disclosures

Beneficial ownership is the heart of it. The order is not satisfied with knowing the name on the entry. It wants to know who is behind it.

2. Restrictions specific to foreign IORs — Sec. 2(b) and 2(c)

This is the section most summaries skip, and it is the one that changes planning.

For informal entries: a foreign IOR is prohibited from filing informal entry (Sec. 2(b)).

For formal entries — which is what a full container is — a foreign IOR:

  • may not rely on a continuous bond to satisfy the entry bond requirement, except where CBP permits it on a showing that the revenue would be fully protected and compliance assured; and
  • must be validated in CTPAT (if CBP determines it eligible), or use a CTPAT-validated and licensed customs broker to file entries (Sec. 2(c)).

Read that carefully. A foreign IOR is not banned. It is pushed onto a narrower path: a different bond structure, plus either CTPAT validation or a CTPAT-validated broker.

3. “Good standing” — Sec. 2(d)

All IORs must maintain “good standing” with CBP, measured by the compliance history and duty payment record of the IOR and its affiliates.

An IOR not in good standing may not import, and may not designate a customs broker to act as IOR on its behalf.

That second clause is the one that ends the practice of borrowing someone else’s importer number. If that number loses good standing, the cargo on it has no path to entry — regardless of whether the cargo itself is clean.

4. The IOR registry is being rebuilt — Sec. 2(e)

CBP is directed to:

  • remove inactive IORs
  • confirm active IORs comply with all disclosure requirements
  • create risk-based tiers based on compliance history, enforcement actions and audit results

5. Everyone around the IOR is vetted too — Sec. 2(f)

Enhanced vetting, including recurrent vetting, applies to:

  • foreign IORs
  • affiliates of IORs
  • customs brokers
  • custodians of bonded merchandise
  • freight forwarders

Freight forwarders are named in the order. We are not observers of this.

6. Penalties were restructured — Sec. 4(c)

  • a minimum penalty floor of not less than 50 percent of the assessed penalty, absent exceptional circumstances
  • a minimum liquidated damages floor
  • no mitigation for repeat offenders

The order states the reasoning directly: some actors had been treating penalties as a cost of doing business and applying for mitigation as a matter of course.

Why borrowing an importer number no longer works

The old structure was simple: the cargo belongs to A, the entry is filed under B, and if anything goes wrong B abandons the container and disappears.

The order closes that structure in four places.

Good standing is not individual — it is attached. Sec. 2(d) says an IOR out of good standing cannot import and cannot appoint a broker to file on its behalf. One flagged number takes down every container filed under it.

Beneficial ownership disclosure ends the anonymity. Sec. 2(a) requires beneficial ownership reporting; Sec. 10(c) directs that CBP guidance prioritise preventing shell companies, sham transactions, or artificial structuring from qualifying as a U.S. IOR.

The penalty floor removes the economics of abandonment. A minimum 50% floor with no mitigation for repeat offenders changes the arithmetic of walking away.

And the clock is the expensive part. IOR verification takes far longer than a routine exam. Demurrage and detention accrue daily while it runs, and those charges land on the cargo owner.

The three legitimate structures — and what the order adds to each

The order is not trying to eliminate importers without a U.S. office. It is trying to eliminate importers that cannot be located, cannot be held accountable, and hold no assets.

Structure A — Non-Resident Importer (NRI)

How it works: your own company, wherever it is organised, obtains a U.S. importer number and a bond, and acts as the IOR.

What Sec. 2(c) adds:

  • no reliance on a continuous bond, unless CBP grants an exception on a revenue-protection showing
  • CTPAT validation, or a CTPAT-validated and licensed broker filing the entries

Be clear about what this means: NRI is not a loophole and it is not a guaranteed green channel. It is a defined path with verifiable requirements. Whether it fits your business depends on your volume, your bond arrangement and your willingness to go through CTPAT — and on CBP’s actual determination in your case.

Structure B — A genuine U.S. IOR

How it works: a U.S. entity files as IOR with its own EIN and bond.

What Sec. 10(a) requires of “U.S. IOR”:

an entity organised under U.S. law, located in the United States, and with controlling beneficial owners who are U.S. citizens or lawful permanent residents — or an entity that owns a significant amount of real property in the United States.

And Sec. 10(c) sets a floor for “located in the United States”:

  • a principal place of business in the U.S.
  • a physical presence where significant business activity is conducted
  • sufficient tangible assets in the U.S., considering the scale of the operation

The practical consequence: a U.S. LLC whose controlling owners are not U.S. citizens or LPRs, and which holds no significant U.S. real property, is not a “U.S. IOR” under this definition. It is a foreign IOR with a U.S. address.

“Just register a company” is not a fix. This is the single most common misreading of the order.

Structure C — The actual U.S. buyer clears

How it works: title passes to the U.S. buyer — a distributor, brand, or retailer — and that buyer files as IOR with its own credentials.

This is the most durable structure, because the IOR is the party that actually carries the commercial responsibility.

What a forwarder can — and cannot — do

Sec. 2(f) puts freight forwarders inside the vetting regime. That is not a reason to avoid forwarders; it is a reason to distinguish among them.

What we do:

  1. Map the right IOR structure to your business — by product, volume, DDP vs DAP, FBA vs commercial delivery. If a structure doesn’t fit, we say so.
  2. Pre-file review before the container loads — ISF (10+2), POA, IOR data, HTS classification reviewed at origin, not at destination.
  3. Connect you to CTPAT-validated brokers and U.S. drayage — Structure A depends on CTPAT, so that is where we plug in.

What I will not do: promise that a container will not be examined, or that a structure will “pass.” Under this order, compliance is a set of verifiable facts — bond, validation, disclosures. Not a promise.

The one-line version

CBP is no longer asking for a document. It is asking for a party it can locate, that holds assets, and that can carry the liability.

For structures built on borrowed importer numbers, that is a problem. For importers who keep their entity and their paperwork clean, it raises the cost of the competition.

The question worth answering now is not whether to become compliant. It is: does the IOR structure you are using today still hold up under the way CBP now looks at importers?

Key facts

  • EO 14411, “Strengthening Customs Enforcement,” signed 3 June 2026, published at 91 FR 35125.
  • Scrutiny moved from the cargo to the IOR: domestic assets, bond levels, beneficial ownership, affiliations.
  • Foreign IORs cannot file informal entry; for formal entry they cannot rely on a continuous bond and must be CTPAT validated or use a CTPAT-validated broker (Sec. 2(c)).
  • An IOR not in good standing cannot import and cannot appoint a broker to act for it (Sec. 2(d)).
  • “U.S. IOR” requires controlling beneficial owners who are US citizens or LPRs, or significant US real property (Sec. 10(a)).
  • Penalties carry a minimum 50% floor with no mitigation for repeat offenders (Sec. 4(c)).
  • Customs brokers and freight forwarders are inside the vetting regime (Sec. 2(f)).

Based on the text of the order at 91 FR 35125. Not legal advice. Whether a structure fits your business depends on your product, volume and entity — it needs to be assessed case by case.

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