On June 3, 2026, President Donald J. Trump signed the Executive Order titled “Strengthening Customs Enforcement,” directing the Department of Homeland Security (DHS) and U.S. Customs and Border Protection (CBP) to carry out the most far-reaching overhaul of import requirements in more than a decade (The White House 2026; BDO 2026). For any business that depends on a customs bond to move goods across the United States border, the message is unambiguous: financial accountability and demonstrated compliance are becoming conditions of market access, not afterthoughts. This article explains what the order changes, why it raises the stakes for every importer of record, and how a well-structured customs bond program protects your supply chain.

Why the Executive Order Matters for Your Customs Bond

A customs bond is a financial guarantee that an importer will pay the duties, taxes, and fees owed to the federal government and will comply with applicable trade laws. The new order treats that guarantee as central to enforcement. CBP frames the change in plain terms, asserting that importing into the United States is a privilege rather than a right (U.S. Customs and Border Protection 2026). Consequently, the agency intends to use bonding, asset verification, and vetting to filter out actors who cannot stand behind their import activity.

The order arrives against a backdrop of mounting revenue and security concerns. The administration cites undervaluation of merchandise, incomplete importer identification, and duty evasion schemes as systemic weaknesses that current enforcement tools fail to close (The White House 2026). Importantly for compliant businesses, the order is designed to level the playing field by holding every importer to a verifiable financial standard.

What the Order Changes for Importers of Record

The order reaches both formal entries under 19 U.S.C. § 1484 and informal entries under 19 U.S.C. § 1498 (Brownstein Hyatt Farber Schreck 2026). Several directives stand out for clients who hold or will need a customs bond.

First, the order instructs CBP to require every importer of record (IOR) to maintain a bond, a minimum level of tangible domestic assets, or both, and to raise minimum bond coverage as needed to secure compliance (WilmerHale 2026; The White House 2026). In other words, the continuous bond many importers treat as routine may soon carry higher penal sums tied to duty exposure.

Second, CBP must define and enforce a “good standing” requirement based on an importer’s compliance history, the records of its affiliates, and its payment record (Wiley Rein 2026). An importer that loses good standing may be barred from importing and may be prohibited from designating a customs broker to act on its behalf (Flexport 2026). Therefore, a clean compliance record now carries direct operational consequences.

Third, the order directs an importer registry cleanup. CBP will remove inactive importers, confirm that active importers are compliant, and create risk-based tiers grounded in enforcement history and audit results (BDO 2026). Enhanced and recurrent vetting will extend to brokers, custodians of bonded merchandise, and freight forwarders as well (Wiley Rein 2026).

New Customs Bond and Asset Requirements

The bonding provisions deserve close reading because they reshape the economics of importing. CBP intends to establish minimum tangible domestic asset thresholds and to lift minimum bond amounts so that the agency can reliably collect duties and penalties (WilmerHale 2026). For importers carrying higher tariff exposure, as many do following recent trade actions, existing bond limits may prove inadequate. As a result, an underbonded importer risks entry delays, demands for additional security, or insufficiency determinations from CBP.

The order also strengthens the consequences of noncompliance. It calls for a minimum penalty floor of at least 50 percent of the assessed penalty absent exceptional circumstances, removes penalty mitigation for repeat offenders, and accelerates the seizure and disposal of noncompliant goods, including expedited forfeiture under 19 U.S.C. § 1612 (BDO 2026; Holland & Knight 2026). Higher penalties translate directly into higher bond exposure, which is precisely why surety underwriters and importers should reassess coverage now.

Stricter Rules for Foreign Importers of Record

While the order raises the bar for all importers, it imposes the heaviest restrictions on foreign IORs that lack United States-based assets (Wiley Rein 2026). Foreign importers will be prohibited from filing informal entries, a channel previously available for shipments valued under the 2,500-dollar threshold (Flexport 2026). Moreover, foreign IORs filing formal entries will generally be barred from relying on continuous bonds unless they obtain validation under the Customs Trade Partnership Against Terrorism (CTPAT) program or file through a CTPAT-validated and licensed customs broker (Wiley Rein 2026).

These measures build on the suspension of de minimis treatment for low-value shipments that took effect for all countries in February 2026 (Wiley Rein 2026). Taken together, they substantially constrain the low-value e-commerce import model and push foreign sellers toward stronger domestic representation and bonding. For Surety One, Inc. clients who serve as the United States importer of record for foreign principals, this shift creates both responsibility and opportunity.

The Compliance Timeline Importers Should Track

The order sets aggressive but staggered deadlines. DHS must deliver legislative recommendations to the President within 45 days, by mid-July 2026 (The White House 2026). A ninety day tranche covering penalty revisions, foreign export documentation, disposal procedures, and transparency measures lands in early September 2026 (Holland & Knight 2026). The structural reforms most relevant to bonding, namely asset thresholds, good standing, enhanced vetting, and the registry overhaul, follow at 180 days, by late November 2026 (Holland & Knight 2026; Flexport 2026). Finally, an effectiveness report is due to the President in June 2027 (Flexport 2026).

One caveat matters greatly. Most provisions are not self-executing. The order directs DHS and CBP to develop regulations and policies, much of which must proceed through notice-and-comment rulemaking before specific dollar figures take effect (Crowell & Moring 2026). The direction of travel is firm, yet the exact bond minimums remain to be set.

How to Prepare Your Customs Bond Program Now

Prudent importers should not wait for final rules. We recommend several steps. Confirm that you can substantiate your United States presence and domestic assets to qualify as a U.S. importer of record (Brownstein Hyatt Farber Schreck 2026). Stress-test your current continuous bond against higher-duty exposure and likely minimum increases. Organize ownership, beneficial ownership, and affiliate data in advance of expanded disclosure requirements. Review prior compliance issues that could affect your good standing. Finally, verify that your customs broker holds CTPAT validation, especially if foreign principals are involved (Holland & Knight 2026).

Surety One, Inc. underwrites customs bonds for admitted carriers and works daily with importers, brokers, and foreign principals navigating exactly these questions. As CBP translates the order into binding rules, we will help you right-size your bond, document your standing, and keep your goods moving. To review your customs bond program or request a quotation, contact our underwriting team.

~ C. Constantin Poindexter, MA, JD, CPCU, AFSB, ASLI, ARe, AINS, AIS, CPLP

Bibliography

  • BDO USA. 2026. “Executive Order ‘Strengthening Customs Enforcement’ Signals Sweeping U.S. Import Reform.” BDO Insights. https://www.bdo.com/insights/tax/executive-order-strengthening-customs-enforcement-signals-sweeping-us-import-reform.
  • Brownstein Hyatt Farber Schreck. 2026. “Executive Order Tightens CBP Requirements for U.S. Importers of Record.” JD Supra, June 10. https://www.jdsupra.com/legalnews/executive-order-tightens-cbp-3139152/.
  • Crowell & Moring. 2026. “Executive Order on Strengthening Customs Enforcement.” International Trade Law Blog. https://www.cmtradelaw.com/2026/06/executive-order-on-strengthening-customs-enforcement/.
  • Flexport. 2026. “New Customs Enforcement Executive Order: Key Changes for Importers.” Flexport Blog. https://www.flexport.com/blog/new-customs-enforcement-executive-order-key-changes-for-importers/.
  • Holland & Knight. 2026. “White House Issues Sweeping Customs Reform Executive Order: Key Takeaways for Importers.” Holland & Knight Insights, June. https://www.hklaw.com/en/insights/publications/2026/06/white-house-issues-sweeping-customs-reform-executive-order.
  • The White House. 2026. “Strengthening Customs Enforcement.” Presidential Actions, June 3. https://www.whitehouse.gov/presidential-actions/2026/06/strengthening-customs-enforcement/.
  • U.S. Customs and Border Protection. 2026. “White House Issues New Executive Order to Strengthen Customs Enforcement, Protecting U.S. Consumers and Businesses.” CBP Newsroom, June 3. https://www.cbp.gov/newsroom/national-media-release/white-house-issues-new-executive-order-strengthen-customs.
  • Wiley Rein. 2026. “New EO on Customs Enforcement Tightens Import Controls, Aims to Reduce Evasion.” Wiley Alert. https://www.wiley.law/alert-New-EO-on-Customs-Enforcement-Tightens-Import-Controls-Aims-to-Reduce-Evasion.
  • WilmerHale. 2026. “New Executive Order on ‘Strengthening Customs Enforcement’: What Importers Need to Know.” WilmerHale Client Alert, June 10. https://www.wilmerhale.com/en/insights/client-alerts/20260610-new-executive-order-on-strengthening-customs-enforcement-what-importers-need-to-know.
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