CBP Targets Importer of Record Data for Enforcement Actions

Aug. 18, 2026
By: Pietro N. Bianchi

CBP issued a notice announcing its initial steps to implement President Trump’s recent executive order, Strengthening Customs Enforcement. CBP is “comprehensively reviewing” for accuracy the importer of record (“IOR”) information submitted on CF 5106. CBP’s notice calls out physical address, email address, and phone number as targets for its review.

CBP stated that the physical address must be that of the IOR and not that of a registered agent, customs broker, freight forwarder, a business service center, another person or entity, or, notably, a P.O. box. CBP further stated that the email address and telephone numbers must be valid, belong to the IOR, and not be that of a Customs broker or another person or entity.

In approximately 30 days, if CBP determines that IOR information is inaccurate or incomplete, CBP will “immediately void the associated IOR number.” This would abruptly interrupt all imports.

CBP also cautioned Customs brokers and certifying parties that they may be subject to enhanced enforcement. CBP noted that Customs brokers must exercise due diligence to ensure IOR information is accurate and must execute the POA directly with the IOR. CBP emphasized that fines, imprisonment, liability under the False Claims Act, broker penalties, and other legal consequences may result from making inaccurate, misleading, or intentional false statements on a CF 5106.

Because CBP has notified the importing community of its plans to target IOR information for review, it would be prudent for IORs, Customs brokers, and other certifying parties to review CF 5106 information for accuracy and completeness. And do not hesitate to contact an attorney at Barnes Richardson, & Colburn LLP if you have questions about importer of record information or due diligence.