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The 2026 CBP Trade and Cargo Security Summit signaled a sharp increase in import fraud enforcement. CBP issued 10,000 Importer of Record (IOR) verification notices and 88% of the importers who received one failed to verify themselves. The agency voided 9,000 IORs for non-verification, confirmed 800 cases of stolen identity use, and issued 522 Do Not Load orders at origin (90% unanswered as of September 9, 2026). CBP officials with 20-30 years of experience said they have never seen enforcement at this level. Importers and brokers should expect more frequent identity and documentation verification requests going forward.
Why This Summit Was Different
I attended the CBP Trade and Cargo Security Summit again this year, and I want to share what I heard, how the focus has changed from previous events, who CBP is training its attention on, and why it should be a wake-up call.
The first thing I noticed was a change in who the sessions were intended for. A lot of the programming this year was targeted toward importers rather than brokers. When I asked one CBP official about it, their answer was point-blank: importers needed to understand both their responsibilities and the fact they’re accountable for their actions. Customs wants to make sure importers hear it from them directly, not via their brokers or the press.
What CBP Discussed in the Open Session on the Executive Order
CBP held an open session on this summer’s Executive Order, and officials took questions and comments from the audience. One idea that got real traction was a proposal for an importer portal modeled on what CBSA uses in Canada, where an importer uploads required documentation directly for review before being approved to import. CBP said they weren’t familiar with the CBSA model and committed to looking into it further. If that kind of portal eventually comes to the U.S., it would represent a meaningful shift in how importer vetting works here.
What CBP Said About “Bad Brokers” and Enforcement
Enforcement was the theme running through nearly every session. CBP officials talked repeatedly about “bad brokers,” specifically pointing to filer codes being used outside the U.S. and filer codes shared with non-licensed entities, even after CBP had already flagged the behavior and told the broker to stop. More than one CBP official with twenty or thirty years at the agency said, on the record, that they’ve never seen enforcement at this level before. AI is a big part of why: CBP is using it to flag violators faster and act on them sooner than in years past.
CBP Enforcement Data Shared at the Summit
CBP shared the following figures during summit sessions:
The FBI is currently investigating 160 million stolen identities being used to commit fraud.
CBP has issued 10,000 Importer of Record (IOR) notices to verify who’s actually behind an import, and 88 percent of the importers who received one failed to verify themselves.
CBP has voided 9,000 of those IORs because the importer couldn’t verify their identity or never responded at all.
800 IORs have been confirmed as using stolen identity information.
On the ocean side, CBP issued 522 Do Not Load orders at origin as of September 9, 2026, and 90 percent of those have gone unanswered.
How Document Fraud Is Evolving
Document fraud has gotten more sophisticated too. CBP described seeing photoshopped and AI-generated passports submitted in response to their requests, including one case where a photo of actress Kate Winslet appeared on a submitted passport, and other cases where the same photo showed up on multiple passports tied to different identities. CBP’s language was blunt: the fraud is getting creative.
What Western Overseas Is Doing in Response
I spoke with other brokers and trade attorneys throughout the week, and the sentiment was the same across the board: it’s getting scary. Yet unspoken among attendees was the elephant in the room: the people who’d taken the time, effort, and money to travel to Dallas to hear this weren’t the bad actors the agency was alluding to, so being lectured at left a bit of a bad feeling with everyone.
For our importer clients and those who want to work with us, our takeaway as a brokerage department and as a compliance team is that we’re going to need to do more, and more frequent, due diligence. As Michael Corleone put it, it isn’t personal, it’s strictly business. Our questions are a chance to learn more about our importers, and for our importers, it’s a chance to take a deeper look at their supply chains, and maybe even do the kind of research and proactively make changes that can prevent an investigation somewhere down the road.
If you have questions about how these enforcement trends will affect your import program, or you want a second set of eyeballs on your own internal compliance and vetting processes, reach out to our compliance team. We’re here to help you stay ahead of it.
By Erica Budzilek, VP of Regulatory Compliance, Western Overseas



