Customs Brokers Under Scrutiny: CTPAT, Foreign IORs & CBP’s New Due Diligence Expectations for All Brokers 

The role of the customs broker is changing. President Trump’s June 3, 2026 Executive Order on strengthening customs enforcement directs U.S. Customs and Border Protection (CBP) to impose heightened requirements on importers of record (IORs), including new restrictions affecting foreign IORs and the brokers that represent them. Among the most significant changes, foreign IORs may be required to become CTPAT validated, if eligible, or use a CTPAT-validated licensed customs broker to file formal entries with CBP.  

At the same time, CBP is signaling significantly greater expectations for broker due diligence on ALL IORs, both domestic and foreign. Customs brokers serving foreign IORs may be expected to conduct more comprehensive vetting of both those  clients and the imported goods, including reviewing ownership, business affiliations, compliance history, financial ability to pay duties, and information concerning classification, valuation, country of origin, and the supply chain. These developments come as customs brokers are already facing heightened scrutiny over responsible supervision and control and other broker compliance obligations. 

This webinar will cover: 

  • What the June 3 Executive Order means for customs brokers and foreign importers of record 
  • CBP’s increased focus on responsible supervision and control and what recent enforcement activity means for brokers 
  • CBP’s anticipated heightened broker due diligence and client-vetting expectations for all IORs 
  • What brokers may need to verify regarding foreign IORs, including ownership, compliance history, financial ability, classification, valuation, country of origin, and supply chains 
  • Documentation and recordkeeping considerations for demonstrating broker due diligence 
  • How broker compliance failures can lead to penalties, suspension, or license revocation 
  • Why CTPAT validation may be necessary for customs brokers representing foreign IORs 
  • CTPAT eligibility requirements and the application process, including the Company Profile, Security Profile, Minimum Security Criteria, and CBP validation 
  • Practical steps customs brokers can take to meet current diligence expectations, and how to prepare for the forthcoming rules 

Presenters: 

  • Jennifer Diaz, President, Diaz Trade Law 
  • Dana Watts, Of Counsel, Diaz Trade Law 

Who Should Attend: 

  • Customs Brokers 
  • Importers  
  • Manufacturers 
  • Regulatory Affairs Professionals  
  • In-house Legal Counsel  
  • Product Development Managers  
  • Others interested in Customs Compliance