Trump’s New IOR Executive Order: Tougher Bonds, Continuous Vetting, and New Limits on Foreign Importers of Record

Executive Summary 

On June 3, 2026, President Trump issued an executive order overhauling how Customs and Border Protection qualifies and polices importers of record. The order raises bonding and data requirements, restricts foreign IORs from filing entries unless they meet substance and CTPAT standards, mandates “good standing” with CBP, and extends enhanced, recurrent vetting to brokers, forwarders, and custodians. For importers and their partners, customs compliance is shifting from one-time onboarding to continuous qualification and monitoring.

Intro

Washington just made it harder to be a U.S. importer, and a lot riskier to be one without real roots on American soil. That’s the thrust of Strengthening Customs Enforcement, the executive order President Trump signed June 3 that the White House calls a national security measure. 

The impact is simple to state and big in practice: instead of catching problems after goods enter, Customs and Border Protection will vet importers of record before they ship and keep watching them the whole time they’re active. Foreign-owned importers, anyone bringing goods in through a thin or shell U.S. entity, and the brokers and forwarders who serve them are squarely in scope. 

The one real bit of breathing room is timing. Most of the order tells agencies to “take steps” over 90- and 180-day windows, so it sets direction rather than flipping a switch tomorrow. 

Needless to say, the smart move is to prepare now.

Importing Is Now a Privilege You Have to Keep Earning

Customs summed up the thinking in one blunt line: for too long, importing into the United States has been treated as a right instead of a privilege. So rather than let almost anyone sign up and chase the bad actors later, CBP now wants importers to qualify before they ship and stay qualified the whole time they’re active. Before that spooks anyone, the order doesn’t rewrite the rules by itself. It gives CBP and DHS 90 to 180 days to start, with the binding details arriving through normal rulemaking, as the White House fact sheet confirms. You’re not behind yet, but the direction is set.

The Shell Game CBP Is Trying to End

The crackdown on foreign importers traces back to a loophole CBP has spent years trying to close. A company overseas sets up a U.S. entity that exists mostly on paper, names it the importer of record, ships goods in, and lets the duties go unpaid. By the time Customs goes looking for someone to hold accountable, there’s no real business to find, no office, no staff, no assets within reach. 

Under this executive order, that can no longer happen.

A foreign importer will now have to show it genuinely operates in the United States, backed by a real headquarters, real activity, and assets that could actually cover what it owes. Anyone who can’t clear that bar loses informal entry, faces stiffer rules for formal entry, and has to either earn CTPAT validation or file through a broker who already holds it.

What CBP Will Expect From Every Importer

The foreign-shell rules grab the headlines, but the order quietly raises the bar for every importer. To stay eligible, you’ll likely have to hold real assets in the U.S., post a larger bond, or both, and give CBP a much fuller account of your business, including how much you plan to import, who actually owns and controls it, and how much it holds in domestic assets. 

The biggest change, though, is a new “good standing” requirement that hinges on your record of following the rules and paying your duties. Get caught importing illegal fentanyl, and you’re out automatically. Lose good standing any other way, and you can’t import at all, or pass the job off to a broker to skirt it.

Your Broker and Forwarder Are on the Hook Too

Your broker, your forwarder, and the warehouses holding your bonded cargo don’t get a pass either. The order puts all of them, plus the companies affiliated with them, under ongoing vetting rather than a single check at sign-up. 

Filing an entry will also mean handing over more than before: a certification that you comply with sanctions law, foreign tax and business identifiers, and a real account of how each product is made, down to model numbers and material specs. 

Enforcement is harsher across the board, as well. Mitigation can’t fall below 50%, CBP can audit more often and seize goods faster, and brokers who cut corners on due diligence or keep clearing shipments for noncompliant clients face the steepest penalties of all.

What to Do Before the Rules Catch Up

All of this adds up to one thing: more exposure, on two fronts. The new rules give you more ways to fall short, and with the administration stretching its authority this far, legal challenges will likely keep the details in motion for a while. The encouraging part is that you can get ready now, well ahead of the final rules and the 90- and 180-day deadlines. Five steps will put you in front of it:

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• Get Ahead of CTPAT: If your imports run through an entity with little real U.S. footprint, start the CTPAT process now or line up a CTPAT-validated broker. The order will push you there regardless, and it’s far easier to do on your own schedule than against a deadline.
• Reassess Your Bonds and U.S. Assets: CBP is moving toward expecting importers to back their entries with real domestic assets, a bigger bond, or both. Take an honest look at where you stand today so a higher bar doesn’t catch you short later.
• Map Your Ownership Now: Compliance experts increasingly call ownership and control the question that matters most, so build a clear picture of who really owns your business, down to beneficial owners and affiliated companies. Having it documented means you’re ready the day CBP asks, not scrambling.
• Audit Your Good Standing: Review your compliance record and duty-payment history the way CBP will, since both now decide whether you can keep importing. Cleaning up old issues early keeps you off any risk tier or watch list.
• Tighten Your Product Documentation: Make sure you can show how your goods are made and where they come from, from manufacturer identifiers and specs to solid country-of-origin support. That paper trail is about to carry a lot more weight at entry.

Where Mallory Alexander Comes In

You don’t have to face the impacts of this executive order alone, and you shouldn’t. This type of thing has been our bread and butter at Mallory Alexander for over a hundred years. As a licensed, C-TPAT-certified broker, we’re already the validated partner the new foreign-importer rules will point companies toward, which means working with us keeps you in front of the requirement instead of chasing it.

Because we live in these details every day, the order’s heaviest demands are simply our daily work. Our licensed customs brokerage handles the bonds, classifications, entry filings, and the importer-of-record and foreign-importer work that sit at the center of the new rules, backed by a trade management and compliance team whose duty planning and risk assessments keep your good standing solid well before CBP ever asks. myMALLORY gives you a clear, defensible record behind every entry, and with our warehousing, transportation, and managed logistics under the same roof, tighter compliance never slows the freight.  

Let’s Get You Ready

There’s no reason to wait until the rules are final. Let us review your bonds, your IOR setup, and your path to CTPAT so you’re ready the day they land. Get in touch with our team and let’s talk it through.