What the June 2026 Customs Enforcement Order Means for Importers
The 180-day window is open. Here’s what you need to do before CBP defines the rules.
The White House signed an executive order on June 3, 2026 directing CBP to overhaul how imports are processed, vetted, and penalized. The headline provision: foreign importers of record are now directly in scope. The 180-day countdown started June 3rd.
Who Gets Hit Hardest
Foreign entities acting as importer of record (IOR) face the steepest changes under the order:
- Barred from informal entry — the simplified, lower-cost process used for many lower-value shipments
- Continuous bonds restricted — single-entry bonds or an explicit CBP exception required
- Must use a CTPAT-validated licensed customs broker, or become CTPAT certified themselves
U.S.-based importers are not exempt. Every importer will need to demonstrate “good standing” with CBP — a new status concept covering compliance history, affiliate conduct, payment records, and prior violations.
What “Good Standing” Means in Practice
Within 180 days, CBP will define good standing in formal guidance. Based on the order, it will incorporate:
- Compliance history — including the history of affiliated entities
- Prior customs and trade violations
- Payment history with CBP
- Exposure to forced labor, origin fraud, undervaluation, and transshipment issues
The business risk: a single bad compliance event — even from an affiliate — could affect the ability to import across related entities. Corporate groups need to audit their compliance footprint, not just individual import records.
Why Your Choice of Customs Broker Matters More Than Ever
The order pulls brokers directly into compliance accountability:
- Increased audits of licensed customs brokers
- Maximum penalties for brokers who fail due diligence on clients
- Penalties for brokers who repeatedly represent noncompliant importers
- Required cooperation with CBP investigations and requests
In practice, brokers who are not CTPAT-validated will turn away foreign IOR clients. The ones who are validated — and can demonstrate clean compliance records — will be in shorter supply and higher demand.
Falcone Global’s Position
Falcone Global Solutions and Premio International Services are both Tier 2 Certified and Validated with CTPAT — covering Ocean, Air, and Ground Shipping as well as Licensed Customs Brokerage (Premio International Services). This dual-entity, multi-modal CTPAT validation is uncommon among licensed customs brokers. For foreign importers of record who need a compliant path forward under the new EO requirements, that distinction matters.
What to Do in the Next 90 Days
- Identify your IOR structure. Are any entities in your corporate group classified as foreign importers of record? The order’s new requirements apply at the entity level.
- Audit your bond coverage. Higher bond requirements are coming — continuous bond thresholds will likely rise under forthcoming CBP guidance.
- Review your compliance history. Open CBP enforcement actions need to be resolved before “good standing” is formally defined. Affiliated entity exposure counts.
- Engage a CTPAT-validated broker now. The window to structure your import relationships correctly is before CBP finalizes rulemaking — not after. Not all brokers are CTPAT-validated, and demand will rise as the 180-day deadline approaches.
About Us
Headquartered in Atlanta, GA, Falcone Capital Holdings, LLC is a global leader in international and domestic transportation and logistics. Falcone Capital Holdings operates across six continents through wholly owned subsidiaries and partner offices, and is synonymous with cutting-edge services across all modes of international and domestic transportation. The Falcone Companies are licensed, bonded and insured through all federal and state agencies including Customs and Border Protection, Federal Maritime Commission (FMC), Federal Motor Carrier Safety Administration (FMCSA), Transportation Security Administration (TSA) and Department of Homeland Security (DHS). Falcone Global Solutions and Premio International Services are both Tier 2 Certified and Validated with CTPAT for Ocean, Air and Ground Shipping as well as Licensed Customs Brokerage (Premio International Services).