Gregory Bryant, Esq / CPA
Caroline White, Esq / CPA

EO 14411: 30 Days Away

The 180-day clock on Executive Order 14411 expires at the end of November 2026. Since EO 14411 was signed on June 3, 2026, CBP has moved from announcement to action on several fronts, but the rules that shape the business of foreign importers of record (IORs) have not yet been published. This update summarizes what has happened since June and lays out what to expect and what to do before the deadline. For a detailed analysis of EO 14411, see our previous article, “Executive Order 14411: The End of Drop Shipping?”

Updates Since June

• Form 5106 Enforcement: Effective September 18, CBP reviews Form 5106 data for all IORs and will deactivate the IOR account if the information is inaccurate or incomplete. Addresses, email addresses, and phone numbers must belong directly to the IOR, and a broker submitting the form must hold a power of attorney executed directly with the IOR. Inaccurate data can also lead to broker sanctions and, where false statements support import claims, potential False Claims Act exposure. [1]
• Supply Chain Disclosure Rulemaking: On September 2, CBP published an Advance Notice of Proposed Rulemaking (ANPRM), Heightened Import Disclosures for Supply Chain Visibility, which would implement parts of Section 3 of EO 14411. It poses 64 questions, including whether importers should be required to obtain and submit the documents foreign exporters file with their own customs authorities, whether Global Business Identifiers should become mandatory, and whether CTPAT participants should have to adopt supply chain tracing technology.[2] These questions are open for comments-importers should review them and submit comments before the deadline posted on Regulations.gov-that will be used to draft proposed regulations.
• CTPAT Broker Vetting Guidance: An August CTPAT alert outlines expanded duties for CTPAT-validated customs brokers that file for foreign IORs. Before conducting business for a foreign IOR, a broker is expected to vet its legal identity, ownership, affiliations, US assets, import history, and ability to pay duties, and to keep records of that diligence. Brokers that fall short face potential penalties, audits, or removal from CTPAT.[3]
• 90-Day Mark: September 1 marked 90 days under EO 14411, covering the foreign exporter documentation requirement, revised mitigation standards (including the 50% penalty floor, a liquidated damages floor, and no mitigation for repeat offenders-meaning importers with prior violations may face full statutory penalties), streamlined disposal of non-compliant goods, and customs transparency measures.
• Enhanced CBP Documentation: Customs counsel report a significant uptick in CBP Requests for Information and Notices of Action, with CBP asking for far more documentation to validate import declarations than in the past.[4]
• Amazon Warning to Sellers: Amazon has alerted sellers to potential import changes under EO 14411, particularly sellers who rely on foreign IORs.[5]

What to Expect in December

The items due at 180 days are the most substantive provisions of EO 14411: minimum asset and bond requirements and higher bond minimums, expanded IOR data disclosures, the “good standing” requirement, the updated IOR registry, and enhanced recurrent vetting of IORs, brokers, forwarders, and custodians of bonded merchandise;[6] however, the effective date for compliance with the rules issued at this date will likely be later. The new bonding requirements alone will have a significant and immediate impact on foreign IORs, as CBP will reliance on continuous bonds absent specific approval and, in many cases, will now require costly, transaction-by-transaction single-entry bonds or even cash bonds to ensure adequate protection of U.S. revenue and compliance with CBP requirements.

Additionally, the foreign-IOR restrictions have a different deadline. The informal entry ban and the continuous bond requirements are directed to be issued “promptly,” with no fixed date, meaning foreign IORs should treat these as potentially imminent.[7]

Over the next month, foreign importers should immediately review their existing import structure, verify the accuracy of their Form 5106 information, and evaluate alternative import arrangements if necessary.

[1] https://www.cbp.gov/sites/default/files/2026-09/ctpat_alert_form_5106_compliance_and_enforcement_508_0.pdf

[2] https://www.federalregister.gov/documents/2026/09/02/2026-17926/heightened-import-disclosures-for-supply-chain-visibility

[3] https://www.cbp.gov/sites/default/files/2026-08/ctpat_alert_-_brokers_8_13_26_pbrb_approved_5662-0826_508.pdf

[4] https://www.afslaw.com/perspectives/customs-import-compliance-blog/get-prepared-executive-order-action-cbp-launches

[5] https://myamazonguy.com/news/executive-order-14411-affects-amazon-sellers/

[6] https://public-inspection.federalregister.gov/2026-11595.pdf

[7] https://www.pwc.com/ca/en/services/tax/publications/tax-insights/us-executive-order-customs-enforcement-2026.html#:~:text=%E2%80%9CForeign%20IOR%E2%80%9D%20restrictions,is%20not%20stated