The June 3 executive order significantly tightens U.S. customs rules, raising compliance, disclosure, and penalty exposure for importers—especially foreign importers of record.
The June 3 executive order creates a sharper divide between U.S. IORs and foreign IORs, and it points to stricter vetting, higher bonding expectations, and expanded disclosure requirements.
What changed
The order directs CBP to revise regulations and policies to increase bonding requirements, require minimum domestic tangible assets or bonds, and expand disclosure of ownership, beneficial ownership, affiliations, domestic assets, and expected import volumes.
It also states that foreign IORs should no longer be treated the same as U.S. IORs, including a prohibition on foreign IORs filing informal entries.
Why it matters
For finance leaders, the biggest impact is likely to be cost and risk exposure: more bond pressure, more documentation, and greater scrutiny of who is legally responsible for imports.
For supply chain teams, the practical concern is operational disruption if importer structures, broker relationships, or entry methods need to change to remain compliant.
Compliance priorities
CBP is also directed to establish a “good standing” standard tied to compliance history and payment of customs liabilities, and inactive or noncompliant IORs may be removed from the registry.
The order further signals stronger enforcement around undervaluation, misclassification, transshipment, forced labor, bond claims, and penalties for brokers and repeat offenders.
What to do now
Importers should review whether their IOR structure, ownership records, bond coverage, and entry processes would withstand heightened scrutiny under the new framework.
They should also prepare for more detailed certification and supply chain disclosure requests, including foreign tax or business identifiers and product-level documentation.
This is a strong moment to audit customs data quality, broker oversight, and importer-of-record governance before the new rules are fully implemented.
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