CBP Is Turning Customs Brokers Into the Front Line of Enforcement — Here's Why We're Asking You More Questions

If your customs broker has suddenly started asking for more documentation than usual — proof that the person who signed your power of attorney is actually a company officer, confirmation of your ownership structure, or backup for the address on file with CBP — you're not imagining it, and it's not just your broker being difficult. U.S. Customs and Border Protection is quietly shifting a large share of import enforcement onto the brokers themselves, and trade press this week is reporting that the shift is landing hard.

What happened

On June 3, 2026, President Trump signed Executive Order 14411, "Strengthening Customs Enforcement," directing CBP to tighten importer eligibility rules, clean up the importer-of-record registry, and lean more heavily on customs brokers to police their own client base. CBP has been implementing that order in stages ever since:

• August 12, 2026: CBP issued a CTPAT alert directing CTPAT-validated customs brokers (CVCBs) to perform comprehensive due diligence on importer clients before conducting any customs business — verifying legal identity, ownership structure, business affiliations, U.S. assets, compliance history, and even the client's ability to pay duties, taxes, and fees.
• August 18, 2026: CBP publicly confirmed that under EO 14411, foreign importers of record must either be CTPAT-validated themselves or use a CTPAT-validated broker to file formal entries — effectively making CTPAT validation a competitive necessity for brokers going forward.
• August 19, 2026: CBP published a Federal Register general notice announcing that, starting September 18, 2026, it will immediately void an importer-of-record number if the physical address, phone number, email, EIN, or SSN on file (CBP Form 5106) is inaccurate, incomplete, or belongs to a broker, registered agent, or P.O. box instead of the importer itself.
• August 25–26, 2026: Trade publications including International Trade Today report that former CBP and DHS enforcement officials expect brokers to be penalized for "lack of supervision and control" if they don't tighten power-of-attorney verification — specifically confirming that whoever signs a POA is actually authorized to sign on the company's behalf, something current regulations don't spell out in detail.

Carrie Owens, a former senior CBP/DHS enforcement official now at Kelley Drye, told trade press this week that CBP likely already has a list of "problem" addresses where hundreds of shell companies have registered, and that the Form 5106 cleanup is designed to shut that pattern down. Customs consultant Tom Gould added that CBP simply doesn't have the staff to vet every importer itself, so it's pushing that job onto brokers — and will hold every broker to the same standard.

What it means for importers

For small and mid-size importers who aren't running shell operations, none of this changes what you owe or how your goods are classified. But it does change how your broker relationship works day to day:

• Slower onboarding. Expect your broker to ask for documentation — corporate registration, proof the POA signer is an officer, IRS EIN confirmation, and a real business address — before setting up a new account or transferring an existing one.
• Harder to switch brokers quickly. Because every CTPAT-validated broker now has to run this vetting independently, moving your account between brokers will take longer than it used to. Plan ahead if you're shopping for a new broker.
• Real financial exposure if your Form 5106 is wrong. Beginning September 18, an inaccurate 5106 can get your importer-of-record number voided outright — not flagged, voided. Baker Tilly's Danae Helgeson warned this could mean unplanned storage and demurrage charges while you sit unable to import, and that reactivation is unlikely to be quick.
• More scrutiny if you use a foreign registered agent's address. If your IOR record lists your broker's, freight forwarder's, or registered agent's address instead of your own operating address, that's now a red flag CBP has specifically called out.

Next steps

1. Ask your broker to pull your current CBP Form 5106 / bond query information and confirm the physical address, phone number, email, and EIN on file are genuinely yours — not a P.O. box, broker address, or agent's address.
2. Confirm who signed your power of attorney and make sure that person's authority to bind the company is documented (a corporate resolution or officer certification is the safest bet).
3. If you're a foreign importer of record, find out now whether your broker is CTPAT-validated — EO 14411 will eventually require it for formal entries filed on your behalf.
4. Don't wait until September 18. Fixing inaccurate 5106 data now avoids the risk of a voided IOR number, unplanned warehousing costs, and a reactivation process nobody expects to be fast.