Article

Customs enforcement executive order reshapes importer requirements

Focus shifts to importer accountability and supporting data

June 10, 2026

Executive summary: Customs enforcement executive order

A June 3 executive order shifts how U.S. Customs and Border Protection evaluates import compliance, with greater emphasis on the importer’s structure, financial capacity and supply chain visibility.

For importers, the implications affect how importer roles are structured, how bonding is supported and how data supports each filing. Companies may face higher bonding requirements, expanded disclosures and closer scrutiny of how importer-of-record structures align with financial responsibility. Enforcement is also expected to become more consistent, with less flexibility in resolving issues.

Although detailed requirements will be established through rulemaking, the underlying shift is evident. Organizations that reassess importer structures, evaluate financial exposure and strengthen the data supporting their filings will be better positioned to adapt as expectations become more defined.

Customs enforcement executive order: What it means for importers

An executive order on strengthening customs enforcement signals changes in how the United States approaches import compliance. Signed June 3, the order points to a broader focus on the importer—not just the accuracy of individual entries—as U.S. Customs and Border Patrol (CBP) evaluates financial capacity, compliance history and supply chain transparency.

For businesses that rely on cross-border trade, this shift carries practical implications. Importers may face higher financial requirements, expanded reporting obligations and closer scrutiny of how their operating models are structured, particularly where nonresident entities are involved.

Importantly, the order sets policy direction rather than detailed rules. CBP is expected to define thresholds, requirements and timelines through rulemaking over the coming months.

In the meantime, the regulatory direction is apparent: Companies will be expected to demonstrate stronger financial backing, clearer supply chain visibility and the ability to support their compliance positions with reliable, auditable data.

Customs enforcement executive order: Key changes

The order sets a policy direction for how import compliance will be evaluated and enforced, with details to be defined through upcoming rulemaking. At a high level, the order points to several key changes, including:

Greater focus on the importer, not just the transaction: CBP is directed to evaluate the importer’s overall profile, including financial capacity, ownership structure and compliance history.
Stricter requirements for importers of record: Importers may need to maintain minimum U.S. assets, higher bond coverage and expanded disclosures, with continued import privileges tied to “good standing.”
Additional restrictions on foreign importers: Foreign, or nonresident, importers face limits on informal entry and tighter requirements for formal entry.
Expanded data and supply chain transparency: Agencies are expected to collect more detailed information on ownership, operations and supply chains, along with additional certifications.
More consistent enforcement: Agencies are directed to increase audits and apply penalties more uniformly, with less flexibility for mitigation.
Greater emphasis on financial assurance: Bonding requirements are expected to increase and align more closely with duty exposure.

Why customs compliance changes will affect operating models

The order connects import compliance more directly to financial exposure, importer structure and day-to-day operations. For many companies, those connections extend beyond the trade function.

Financial and enforcement exposure increases

The order places greater weight on an importer’s ability to meet its obligations. Higher bond requirements and minimum penalty thresholds reduce flexibility when issues arise.

As enforcement becomes more consistent, outcomes are less negotiable. That shift brings customs compliance closer to treasury and risk management, where bonding levels and entity structure influence day-to-day decisions.

Importer structure becomes a strategic consideration

The order increases scrutiny of how companies establish their importer of record. Requirements tied to financial backing, validation and entry methods place more emphasis on where responsibility sits and how it is supported.

Structures that rely on a limited U.S. presence face closer examination. As a result, importer designation becomes more of a structural decision tied to legal and financial accountability.

Data and supply chain visibility take on a larger role

Expanded disclosure requirements increase expectations for data quality and consistency. Importers may need to provide more detailed information on sourcing, ownership and product characteristics.

Many organizations rely on disconnected systems or manual processes. Those approaches are harder to sustain as reporting requirements expand. Reliable, traceable data becomes part of demonstrating compliance, especially when information must align across jurisdictions.

What importers should do now to prepare

Although the order outlines direction instead of final rules, it provides enough clarity for companies to begin preparing. The most immediate value comes from identifying where current operating models, financial structures and data processes may not align with a more demanding enforcement environment.

: The order places greater responsibility on the importer of record, particularly where entities have limited U.S. presence. As expectations around financial backing and validation increase, importer designation becomes more closely tied to enforceability.

Mapping current importer arrangements against these expectations can highlight gaps in legal ownership, financial capacity or operational control.

: Bonding requirements are likely to increase and align more closely with duty exposure. That shift brings additional focus to how import activity is financially supported.

Reviewing bond levels in the context of import volumes and potential liabilities can help identify where coverage may no longer match risk.

: As enforcement becomes more consistent and penalty flexibility decreases, the quality of underlying documentation matters more. Areas such as valuation, classification and country of origin remain central to risk.

Organizations that can clearly support these positions with consistent documentation are better prepared for audits and enforcement actions.

: Expanded disclosure requirements increase expectations for data quality and consistency. Importers may need to provide more detailed information on sourcing, ownership and product characteristics.

Evaluating how this data moves across systems can help identify inconsistencies and reduce friction when responding to regulatory requests.

: Many details will be defined through CBP rulemaking, including thresholds, definitions and timing. Staying close to these developments helps companies anticipate how changes will apply in practice and adjust early where needed.

How an advisor can help companies respond to stricter customs enforcement

The order puts more weight on whether import activity can be supported, not just reported. That increases the importance of how importer roles are set up, how obligations are backed and how well the underlying data holds together.

In practice, that pressure shows up in a few places. Importer-of-record structures do not always align with where financial responsibility sits or how transactions are controlled. Bonding may not reflect current exposure. And the data behind entries—valuation, origin, and product details—often moves across systems and among supply-chain partners (customs brokers, freight carriers, suppliers) in ways that do not fully reconcile.

An advisor can help address these gaps as follows:

Clarify importer roles and responsibility, making it easier to demonstrate accountability if challenged
Evaluate bonding against actual exposure, helping ensure financial coverage reflects current risk
Trace how data supports filings, improving consistency and response time during reviews
Identify patterns across entries, surfacing recurring issues before they escalate

Companies that take a closer look at structure, financial support and data now are better positioned to adjust as requirements become more defined.

RSM contributors

Mark Ludwig

National Leader, Trade and Tariff Advisory Services

View full bio >
Bryan Lathbury

Manager

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