Executive Order 14411, Strengthening Customs Enforcement, signed in June 2026, is expected to bring changes for Customs Brokers and foreign Importers of Record (IORs).
Among its many provisions, the Executive Order requires foreign IORs to either a) be CTPAT-validated, or b) use a CTPAT-validated licensed customs broker to file entries with U.S. Customs and Border Protection (CBP).
For customs brokers participating in the Customs Trade Partnership Against Terrorism (CTPAT) program, the changes create both opportunities and new compliance obligations.
What Does This Mean for CTPAT-Validated Customs Brokers?
The new requirements will provide a clear competitive advantage for CTPAT-validated customs brokers (CVCBs).
Eligibility for CTPAT for foreign IORs is limited – at present, Non-Resident Canadian Importers are the only category of foreign importers eligible to join the program as importers. As a result, many foreign IORs will need to rely on a CVCB to maintain access to the U.S. market under the EO’s new framework.
At the same time, CTPAT has stated that there will be heightened expectations regarding broker due diligence.
According to a CTPAT Alert issued on August 12, 2026, CVCBs will be expected to conduct comprehensive vetting of foreign clients before conducting customs business on their behalf. CVCB due diligence is expected to include verification of:
- Legal identity
- Ownership structure
- Business affiliates
- U.S. assets
- History of compliance and import activity
- Ability to pay duties, taxes, and fees
- Details regarding supply chain
- Product classification, valuation and country of origin
Additionally, CVCBs will be expected to be able to demonstrate appropriate due diligence has been conducted by maintaining records of the vetting process, powers of attorney, and all relevant communications.
When Will the New Expectations Take Effect?
Many details are still developing, and specific timelines have not been made publicly available.
The relevant section of EO 14411 requires that the Secretary of Homeland Security “take steps to revise importer eligibility regulations, guidance, and policies” within 180 days of the EO.
Similarly, the CTPAT alert indicates that CVCB will be expected to perform the higher levels of due diligence “in the near future,” but does not provide details on the timeline or standards regarding what CTPAT will consider appropriate due diligence.
We expect that greater guidance will be issued by CTPAT in the coming weeks or months. We would also expect to see updates to the Minimum Security Criteria (MSC) for Customs Brokers.
What Should You Do Now?
If you’re a foreign IOR:
- Confirm whether your current broker is CTPAT-validated.
- Remember: CTPAT-certified and CTPAT-validated are not the same! Once an application is approved by CTPAT, an entity is considered CTPAT-certified. However, they are not CTPAT-validated until they have undergone a validation by CBP. The initial validation must occur within one year of certification.
- If your broker is not already in CTPAT, ask whether they intend to join the program and what their anticipated timeline is.
- Begin gathering documentation that may be requested as part of enhanced broker vetting, such as corporate registration records, ownership information, compliance documentation, and supply chain records.
If you’re a non-CTPAT Licensed U.S. Customs Broker:
- Evaluate the business impact of the upcoming changes.
- You may want to consider joining the CTPAT Program, particularly if a significant portion of your clients are foreign IOR.
If you’re a CVCB:
- Review your current onboarding and vetting procedures for foreign IORs. Evaluate whether your existing procedures may adequately meet the new expectations.
- Proactively engage your Supply Chain Security Specialist (SCSS) to discuss when and how your existing procedures may need to be enhanced.
