U.S. Customs and Border Protection (CBP)

CBP to Implement Fully Electronic Refund Processing via ACE

Effective February 6, 2026, CBP will process all refunds electronically. The agency will not issue any refunds by check unless a waiver has been approved.

Background

Historically, the majority of CBP refunds for the overpayment of duties, taxes, and fees were transmitted via paper checks issued by the U.S. Department of the Treasury. The issuance of electronic refunds via ACH has been available for some time, but opting-in for electronic refunds has been voluntary and limited in scope. In 2024 and 2025, approximately 30% of the refunds CBP issued annually were issued electronically.

On March 25, 2025, President Trump issued an Executive Order titled “Modernizing Payments To and From America’s Bank Account.” The order mandates the transition from paper checks to electronic payments for all Federal disbursements and receipts.

Electronic Refunds

To implement the electronic payments Executive Order, CBP published an Interim Final Rule on January 2, 2026, announcing that the agency will issue all refunds electronically (subject to certain exceptions under 31 CFR part 208) effective February 6, 2026. This rule applies to refunds issued to all importers, brokers, filers, sureties, service providers, facility operators, foreign trade zone operators, and carriers,  and any designated third parties listed on CBP Form 4811. After this date, CBP will not issue any refunds by check, unless a waiver has been approved. Comments on the Interim Final Rule are due March […]

Importer End-of-Year Checklist: How to Strengthen Compliance and Prepare for the Year Ahead

For U.S. importers, the end of the year is a critical moment to evaluate compliance, correct issues, and prepare for the year ahead. With tariff changes, supply chain uncertainty, and an increased focus on enforcement, importers who take a proactive approach now will start the new year strong. Here’s a practical checklist for your year-end review.

1. Review Import Data for Accuracy

Begin with a thorough audit of your import data. Confirm that HTS classifications are correct and current, declared values accurately reflect your transactions, and country-of-origin determinations are well documented. Small mistakes can lead to large penalties.

2. Reassess Tariffs and Duty Exposure

Year-end is the ideal time to evaluate whether you are paying unnecessary duties and explore your options for tariff mitigation strategies. Consider what exclusions have changed, whether tariff engineering may reduce costs, or whether sourcing strategies should be updated. Many importers discover duty-saving opportunities simply by reassessing their tariff positions annually.

3. Strengthen Forced Labor Compliance

With UFLPA enforcement intensifying, importers must confirm that supplier information, ownership structures, and supply chain documentation are up to date. Now is the time to verify traceability records, refresh internal training, and assess whether high-risk suppliers require additional review.

4. Update Written Compliance Procedures

If your compliance manual or SOPs haven’t been updated this year, they’re likely outdated. Written processes should reflect current regulations, product updates, tariff changes, and internal workflow adjustments. CBP expects importers to document their […]

ICYMI: Electronics Company Pays $11.8M to Resolve Duty Evasion Allegations

The Department of Justice announced that Harman International Industries, Inc., an audio electronics company, agreed to pay $11.8M to settle allegations of evading duties on goods made of aluminum from China.

What Happened

For a period of over ten years, from June 2011 to March 2023, Harman knowingly imported heat sinks that contained extruded aluminum from China without paying the required antidumping and countervailing duties (AD/CVD).

The settlement also reveals that when Harman discovered its failure to pay AD/CVD, the company concealed this fact and decided not to disclose it to the U.S. government. 

This case arose from a whistleblower lawsuit filed under the False Claims Act, which permits private parties to file suit on behalf of the United States for false claims and share in a portion of the government’s recovery. The whistleblower in this case will receive over $2M of the settlement proceeds.

Enforcement is a Top Priority for the U.S. Government

High tariffs in the current trade environment have created a higher incentive to cheat. The U.S. government has made clear that enforcing customs laws is a top priority. 

For example, on May 12, 2025, Matthew Galeotti, the Head of the U.S. Department of Justice’s Criminal Division, sent a memo to all criminal division personnel highlighting the focus areas of the division for white-collar crime.

The memo included a […]

New WRO Issued Against Goods Made in Mauritius by Firemount Group

U.S. Customs and Border Protection (CBP) issued a  Withhold Release Order (WRO) against imports made in Mauritius by manufacturer Firemount Group Ltd. (Firemount) after an investigation indicated forced labor use. This WRO was the fourth issued in 2025. CBP now oversees and enforces 54 WROs and nine Findings.

What Happened

On November 18, 2025, CBP issued the WRO against garments, apparel, and textiles manufactured in Mauritius by Firemount. CBP will immediately detain imports subject to the Order. The WRO was issued based on information that reasonably indicates forced labor was used in violation of 19 U.S.C. §1307.

In making this determination, CBP conducted an investigation and analyzed supporting evidence, including interview questionnaires, audio recordings and transcripts, open-source reports from nongovernmental organizations, news media, and academic research.  

The evidence demonstrated that Firemount workers are subject to four International Labour Organization indicators of forced labor: abuse of vulnerability, debt bondage, deception, intimidation, and threats. 

WRO Background 

The strategic use of WROs by CBP has been especially effective at identifying certain nations, industries, and companies that employ forced labor. CBP issues WROs after receiving information that reasonably indicates the use of prison or forced labor at any point in an imported product’s supply chain. Before the Trade Facilitation and Trade Enforcement Act of 2015 (TFTEA), the United States had only implemented 30 WROs in the previous five decades. […]

Jewelry Company Charged in $86M Duty Evasion Scheme

On November 17, 2025, the owner of an Indonesian jewelry company (USB Gold) and two employees were charged with taking part in a scheme to evade over $86 million in duties on jewelry imports. 

The employees were arrested and charged with one count of conspiracy to commit wire fraud and were detained. The company co-owner, who was also charged, remains in Indonesia and has not yet been arrested.

The defendants allegedly engaged in a complex scheme to import over $1.2 billion of jewelry and illegally defraud the United States out of more than $86 million in customs duties and tariffs. 

The alleged scheme included two parts:

  • First, UBS Gold made jewelry in Indonesia and shipped it to Jordan, which had a Free Trade Agreement with the United States, before sending it to the United States. The defendants then falsely claimed that UBS Gold jewelry had been manufactured in Jordan, which avoided the duty that would otherwise apply.
  • Second, when the U.S. announced additional tariffs on Indonesia and Jordan earlier this year, the company began shipping scrap gold from the U.S. to Jordan, which they falsely claimed was gold jewelry that simply needed to be assembled or finished in Jordan. Instead, the defendants and co-conspirators swapped the scrap gold for UBS Gold jewelry made in Indonesia, which they then shipped from Jordan to the U.S. The […]
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