Strengthening Customs Enforcement: A Major Step Toward Foreign-Seller Accountability
The June 3, 2026 Executive Order on Strengthening Customs Enforcement advances core principles AEBA has long championed: foreign sellers must carry real, enforceable accountability inside the United States, and the same rules that bind American businesses must bind everyone who sells into our market. AEBA welcomes this action.
“This Executive Order proves what AEBA has maintained all along: meaningful reform of foreign-seller accountability is achievable through existing executive authority.”
— American E-Commerce Business Alliance
A Foundation of Foreign-Seller Accountability
For years, foreign importers have operated in the U.S. market while keeping their assets, ownership, and liability safely beyond the reach of American law. This Executive Order begins to close that gap — requiring real assets behind every importer, stricter standards for foreign actors, and transparency about who is truly selling into the American market.
It establishes the enforceable, asset-backed, transparent framework that an honest digital marketplace requires — and sets a precedent the Administration can build upon. AEBA welcomes this action and stands ready to support its implementation.
What the Executive Order Delivers
Six enforcement advances that close long-standing accountability gaps in the U.S. customs system — each aligned with AEBA's reform agenda.
Real Assets Behind Every Importer
Importers of Record must maintain a minimum level of tangible domestic assets and bonding — ensuring there is something real on American soil to stand behind every shipment, and someone who can actually be held accountable.
Advances AEBA Reform 05: U.S. Responsible Persons & Liability Bonds, and Priority 03: Mandatory U.S. Entity.
Stricter Standards for Foreign Actors
Foreign importers are barred from informal entries, restricted from relying on continuous bonds without approval, and must be CTPAT-validated or use validated U.S. customs brokers — recognizing that enforcement only works when the responsible party can be reached.
Reflects AEBA's core principle: foreign sellers must carry enforceable U.S. presence and accountability.
Transparency of Ownership
Importers must disclose beneficial ownership, business affiliations, anticipated volumes, and domestic assets — bringing sunlight to who is really selling into the American market.
Supports AEBA Reform 09 (open import records) and Reform 10 (mandatory origin disclosure).
Closing Transshipment & Misclassification Loopholes
Enhanced enforcement against illegal transshipment, undervaluation, and misclassification targets the exact abuses bad actors use to disguise true origin and dodge duties.
Directly advances AEBA Reform 06: Tariffs based on the true country of origin.
Real Penalties With Teeth
Maximum penalties for non-compliant brokers, a 50% penalty floor, and no mitigation for repeat offenders remove the soft landings that made evasion a calculated cost of doing business.
Embodies AEBA's enforcement philosophy: rules without enforcement are no rules at all.
Protecting Families From the Deadliest Abuses
Any importer tied to fentanyl, nitazenes, or illicit precursor chemicals loses good-standing status — striking at the most dangerous exploitation of our import system.
Reinforces the public-safety rationale behind AEBA Reform 16: closing the de minimis loophole.
CBP Confirms What the Order Will Do
U.S. Customs and Border Protection has issued an official alert to licensed customs brokers describing how Executive Order 14411 will change the rules for foreign importers. In the government's own words, here is the stated impact.
Foreign importers must be validated — or use a licensed U.S. broker
Foreign Importers of Record must be validated in the CTPAT program. If they are not, they must use a licensed, CTPAT-validated customs broker to file entries with CBP. CBP states this will hold foreign entities to the same rigorous standards as U.S.-based importers — helping protect national security and the domestic economy from systemic inefficiencies and bad actors.
Comprehensive vetting of every foreign client
Before conducting any customs business, brokers will verify a foreign importer's legal identity, ownership structure, business affiliations, U.S. assets, and history of compliance and import activity. They will assess the importer's ability to pay duties, taxes, and fees, and verify the supply chain, product classification, valuation, and country of origin — keeping thorough records of the vetting, powers of attorney, and communications.
Importers must maintain “good standing”
Every Importer of Record must maintain good standing with CBP. Importers who lose good standing may be prohibited from importing goods, or from designating a broker to act on their behalf.
Real penalties, with a hard 50% floor
Brokers who fail to conduct required due diligence, repeatedly represent non-compliant or unverifiable clients, or fail to cooperate with CBP face financial penalties, increased audit frequency, and possible suspension or removal from CTPAT. The Order sets a minimum penalty floor of 50 percent of the assessed penalty and eliminates mitigation for repeat offenders.
A clear advantage for accountable brokers
Because foreign importers who are not validated themselves must use a CTPAT-validated broker to file entries, CBP expects these brokers to become the primary — and in some cases the only — viable option for a growing share of U.S. imports. CTPAT validation becomes a badge of trust in a more secure trade environment.
Source: U.S. Customs and Border Protection (CBP), CTPAT Alert on Broker Responsibilities Under Executive Order 14411, August 12, 2026.
How the Executive Order Advances AEBA's 16-Point Reform Package
The Order reinforces six of AEBA's reform priorities — operationalizing foreign-seller accountability through existing customs authority.
AEBA Reform Point
Executive Order Provision
Impact Level
Reform 05: U.S. Responsible Persons & Liability Bonds
Minimum tangible domestic assets & bonding for importers
Reform 06: True Country-of-Origin Tariffs
Enhanced enforcement against illegal transshipment
Reform 09: Open Import Records
Annual enforcement transparency reports
Reform 10: Seller & Product Origin Disclosure
Mandatory beneficial-ownership disclosure
Reform 16: Close the De Minimis Loophole
Loss of good standing for fentanyl-linked importers
Priority 03: Mandatory U.S. Entity + EIN
Stricter standards & verified presence for foreign IORs
The Administration is acting on accountability.
Let's build on the momentum.
This Executive Order establishes the enforceable, asset-backed, transparent framework an honest digital marketplace requires. Section 8 of the Order invited legislative recommendations to go further — and AEBA has answered with a companion roadmap that carries this same spirit of accountability into the platforms, warehouses, and payment networks that now drive modern commerce.