特朗普总统命令美国海关和边境保护局加强对记录在案的进口商的监管

June 2026 On Wednesday, June 3, 2026, President Trump issued an executive order (EO), titled“Strengthening Customs Enforcement,” along with a factsheet. The EO concerns tightening The expressed intended goal of the EO is to enhance customs enforcement to prevent importation of unlawful and dangerous goods,ensure IORs are correctly identified, available and accountable for duties owed, and guarantee compliance with existing law. Instructions to US Customs and Border Protection (CBP) regarding both domestic The EO targets all IORs, whether they are foreign or domestic, but imposes additional requirements on foreign IORs due to theirperceived increased threat to US economic and national security interests. The EO’s instructions to CBP when promulgating •Enhance transparency by requiring periodic review andexpiration of confidentiality requests and publishing annual Within 180 days of the order: •Require that IORs have a minimum amount in tangibledomestic assets (e.g., capital in US bank accounts), securea higher minimum surety bond coverage amount, or both. Within 45 days of the order: •Require that all IORs are clearly identified as legitimateentities by providing CBP with data such as importvolumes, ownership disclosures and any other information •Submit legislative recommendations to the president to Within no specified period: •Establish heightened import disclosure and certificationrequirements, including providing information about •Require that all IORs are in “good standing” with CBP, whichCBP will define on an individual IOR basis. “Good standing” •Enhance enforcement by maximizing penalties andliquidated damages, restricting in-bond utilization, and •Update the IOR registry by removing inactive IORs,confirming active IORs are compliant with CBP regulations In addition to the above, the instructions to CBP includeestablishing even more restrictions on foreign (i.e.,nonresident) IORs, including that CBP promptly: •Establish a system of enhanced and continuous vetting of •Prohibit foreign IORs from utilizing the informal entry Within 90 days of the order: •Require IORs to submit any documentation or informationsubmitted to a foreign customs administration to CBP prior •Prohibit foreign IORs from relying on continuous bonds,unless the foreign IORs can demonstrate US domesticassets and connections such that revenue is fully protected •Reduce penalty or liquidated damages mitigation potentialby establishing a minimum floor of at least 50% of the •Require foreign IORs to join CBP’s Customs TradePartnership Against Terrorism (CTPAT) system or use aCTPAT customs broker when filing entries. •Expediate, streamline and enhance seizure and disposal ofnoncompliant entries. Potential targets of the EO and theproposed changes for IORs Definition of “US IOR” and “foreign IOR” The president’s EO places specific, stringent requirements onwhat entities the administration considers as US IORs. TheEO defines the term “US IOR” as an entity that is (1) organizedunder the law of the US; (2) located in the US; and (3) alwayshas a controlling beneficial owner who is a US citizen or lawful One of the most obvious target groups for the EO andproposed changes to the rules for IORs would be foreignrespondent companies involved in antidumping andcountervailing duty (AD/CVD) cases. It has become almostthe norm for foreign respondents to set up stand-alone IORs(wherein the foreign exporters also serve as foreign IORs)or shell companies that serve as IORs, so to insulate the Conversely, a “foreign IOR” is an entity that is (1) notorganized under the law of the US; (2) not located in the US;and (3) does not always have a controlling beneficial ownerwho is a US citizen or lawful permanent resident, or does not As a result, even if entities are organized under the law of theUS and obtain a legal right to make entry, the EO seeminglydirects CBP to consider additional factors to determinewhether an entity is to be beneficially treated as a US IOR The public statements from the administration and muchof the initial press on the EO call out protecting the publicfrom “unsafe or dangerous products.” There has been a lotof talk in recent years about “abuse” of an IOR for productsregulated by the US Food and Drug Administration. Thispractice involves illegally or improperly assigning a party Impact on all IORs The president’s EO outlines unprecedented shifts in compliancerequirements for all IORs. If CBP can enforce regulationspromulgated pursuant to this EO (and if the rules are not struckdown, or at least softened by legal challenges), it will usher in amuch more challenging environment for IORs. Acting as an IORon entries of goods will result in more money being expended Section 2(b) of the EO is noteworthy in that it prohibits foreignIORs from making informal entries. This provision appears tobe directed, at least in part, at foreign e-commerce platformsthat are now selling into the US. They routinely use si