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An Importer of Record (IOR) is the legally designated entity or individual responsible for ensuring that imported goods comply with all US laws and customs regulations. Apparently, people may not be particularly meticulous about disclosing required information about the IOR. Here’s an excerpt from this Stinson memo:

On August 19, 2026, U.S. Customs and Border Protection (CBP) published a General Notice announcing the agency intends to take action against importers (or their customs brokers) who have provided inaccurate Importer of Record (IOR) information on file with CBP. The publication of this notice signifies that CBP is moving swiftly to implement the June 3, 2026, Executive Order (EO) 14411, “Strengthening Customs Enforcement.”

In order to obtain an IOR number and begin importing goods into the United States, individuals or entities (or a customs broker acting on behalf of an individual or entity) must provide identifying information, including a physical address, an email address, a phone number and a tax identification number on CBP Form 5106.

According to the notice, all information on CBP Form 5106 MUST be accurate, complete and belong directly to the IOR.

The memo notes that CBP is starting to verify the accuracy of IOR information on file and highlights the potential consequences of non-compliance. These may include enforcement actions under the False Claims Act. The memo also says that company’s shouldn’t expect leniency for errors in an importer’s IOR profile due to outdated information or clerical errors.

– John Jenkins