On June 3, 2026, the Administration issued an Executive Order on Strengthening Customs Enforcement, which represents a clear shift toward greater importer accountability, supply chain transparency, and enforcement rigor.
While many of the EO’s directives require implementing regulations and additional CBP guidance, the message is clear: importers, brokers, freight forwarders, and other supply chain stakeholders should expect heightened scrutiny, enhanced vetting, and more aggressive enforcement.
For CTPAT members, the good news is that many of the anticipated requirements align closely with existing program expectations. However, companies that have treated the CTPAT Minimum Security Criteria (MSC) as a “check-the-box” exercise may need to reassess their approach.
We break down the key reforms, what they mean for industry in general, and what they mean for CTPAT members.
Key Reforms
Bond coverage requirements: CBP will take steps to revise importer eligibility, including increasing minimum required bond coverage for an Importer of Record (IOR).
- What this means for companies: Importers should evaluate their current bond coverage now and determine whether existing bond amounts will remain adequate under potential new requirements.
Informal entries for foreign IOR: Foreign IORs will be prohibited from filing informal entries (i.e. de minis and low value shipments).
- What this means for companies: Cross-border e-commerce operations and consolidation models that rely on foreign IORs for informal entry processing should begin evaluating alternative import structures.
Formal entries for foreign IOR: For formal entries, foreign IORs will lose access to continuous bonds unless CBP confirms revenue protection. Foreign IORs will also be required to be CTPAT-validated (if eligible) or use a CTPAT-validated, licensed customs broker.
- What this means for companies: Foreign IOR should start CTPAT enrollment and/or broker vetting.
- NOTE: A company that is CTPAT-certified is not necessarily CTPAT-validated. Organizations should confirm their status and understand the distinction.
Good standing: All IORs to maintain “good standing” with CBP, which will factor in compliance history, payment of duties, and enforcement actions of the IOR and its affiliates. IORs not in good standing – such as those tied to importation of fentanyl or other illicit substances – cannot import or use a customs broker as an IOR on their behalf.
- What this means for companies: Importers should conduct internal reviews of their compliance history and evaluate any potential risks associated with affiliates and related entities.
IOR registry: CBP will update the IOR registry, including removing inactive IORs and confirming active IORs are compliant; and creating risk-based tiers for IORs based on compliance history, enforcement actions, and audit results.
- What this means for companies: Importers – particularly those that have never undergone formal CBP vetting – should anticipate outreach and documentation requests, even if compliance history is solid.
Recurred vetting: CBP will establish enhanced vetting procedures, including recurrent vetting, for all parties involved in importation – foreign IORs, affiliates of IORs, customs brokers, custodians of bonded merchandise, and freight forwarders.
- What this means for companies: Brokers, forwarders, and other customs stakeholders should proactively assess their compliance programs and documentation practices.
Supply chain disclosures: CBP will establish heightened import disclosure and certification requirements, include certifying compliance with critical supply chain requirements (such as forced labor statues); disclosing certain foreign tax and global business identifiers; and providing detailed information about the imported good’s supply chain and production methods.
- What this means for companies: Importers should prepare for increased demand for supply chain transparency and be ready to provide detailed supporting documentation at the time of entry.
Foreign export data: CBP will establish a requirement mandating the submission of any documentation or information that the foreign exporter was required to submit to the foreign customs administration prior to exporting to the United States.
- What this means for companies: Importers should establish processes now for obtaining export records and supporting documentation from overseas suppliers and business partners.
Enforcement: Entities should expect CBP to take a stronger enforcement stance, including in the conditions necessary for participation in the CTPAT program. CBP will:
- Enforce liquidated damages on bonds for noncompliance
- Restrict in-bond utilization
- Increase audits
- Impose maximum penalties for brokers failing to conduct due diligence
- Prioritize enforcement against products produced by force labor and imports involving misclassification, undervaluation, and illegal transshipment
- Establish a minimum penalty floor of no less than 50% of the assessed penalty
- Eliminate penalty mitigation for repeat offenders
- What this means for companies: Organizations should expect greater accountability and reduced tolerance for compliance failures across the supply chain.
What This Means for CTPAT Members
For many current CTPAT members, the EO reinforces practices that are already part of a mature supply chain security and compliance program.
Many members are already positioned to meet several of the anticipated requirements because they maintain:
- Documented supply chain security processes
- Supplier vetting and monitoring programs
- Detailed visibility into sourcing and production activities
- Demonstrated commitment to customs compliance
Participation in CTPAT may also serve as a strong indicator that a company and its supply chain partners are operating in good standing with CBP.
However, the EO also signals that the “check the box” approach to CTPAT membership may no longer cut it. The future will favor companies that can not only demonstrate compliance but also actively prove the effectiveness of their supply chain security and trade compliance programs.
