Strengthening Customs Enforcement

EO 14411 Implementation Tracker

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Key Takeaways

    The Deadlines

    The order counts deadlines from June 3, 2026; deadline dates are DTL calculations. Most provisions direct DHS to "take steps" by the deadline, so a passed date does not by itself mean a new requirement binds importers.

      Filled navy markers have passed. The highlighted orange marker is next. Orange outlines are upcoming.

      What CBP Has Published

        Section-by-Section Tracker

        Each card paraphrases the order (91 FR 35125) and reports the implementing action, if any, located in the Federal Register or CBP publications. "No published action located" means we did not find one; it does not mean DHS has not begun work. Analysis labeled DTL's Read is ours, not CBP's.

        Who
        Status

        U.S. IOR or Foreign IOR?

        Section 10 of the order defines a "U.S. IOR" and treats every other IOR as a "foreign IOR." For an entity, the order requires organization under U.S. law, location in the United States, and controlling beneficial owners who are U.S. citizens or lawful permanent residents at all times; alternatively, an entity that owns a significant amount of real property in the United States, as determined by the Secretary, qualifies. Screen each importing entity with these questions.

          DTL's Read: A U.S. subsidiary with a U.S. EIN is not automatically a U.S. IOR under this definition. Foreign-owned U.S. entities that fail the beneficial ownership prong and do not own significant U.S. real property should plan as if the foreign IOR provisions will apply until the Secretary's guidance says otherwise.

          Action Plan by Party

          These recommendations are DTL's analysis. "Prepare for" items track provisions without a published implementing rule.

          DTL's Read on penalties: Section 4(c) directs revisions to CBP's mitigation standards. The prior disclosure penalty limits in 19 U.S.C. 1592(c)(4) are set by statute. For importers who find an error, a prior disclosure filed before CBP opens an investigation remains the most predictable way to limit penalty exposure.

          Comments due December 1, 2026

          Your chance to shape the supply chain disclosure rule

          CBP stated that comments on its ANPRM (91 FR 56408) will be used, potentially, to draft a notice of proposed rulemaking. CBP asks:

          • Whether requirements should be phased in by entry type, commodity, country, or mode of transportation, and whether different timelines should apply to small entities, foreign importers, CTPAT participants, or high-volume filers.
          • About costs and benefits for small businesses and ways to mitigate costs and supply disruptions (Q62).
          • How long it takes to obtain foreign export documentation from suppliers, and what providing it would cost (Q16, Q18).

          CBP stated the most useful comments provide reasons and data and cite question numbers. DTL's Read: comments that quantify per-entry cost, supplier lead times, and effects on small importers give CBP the record it asked for.

          Comment on regulations.govHave DTL prepare your comment

          What to Watch Next

          Section 12(b) states that the order shall be implemented consistent with applicable law, including the Administrative Procedure Act. We expect to see:

            Frequently Asked Questions

            How Diaz Trade Law Can Help

            Diaz Trade Law represents importers, customs brokers, and foreign companies in CBP matters including IOR number voiding and reestablishment, penalties and liquidated damages, seizures, prior disclosures, and compliance program design. We can review your Form 5106 and POA chain, screen your importing entities under Section 10, and prepare comments on the ANPRM.

            Call 305-456-3830Email info@diaztradelaw.com

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