What the Order Fixed — and What It Left Open
The Executive Order rebuilt the importer and enforcement foundation. A point-by-point review against AEBA’s reform agenda shows where the work is done — and that the remaining gaps cluster almost entirely in the platform, tax, logistics, and data layers of modern commerce.
Addressed
Partially
Not Addressed
Importer & Enforcement Foundation
What the Order does well. The importer, bonding, and penalty regime is substantially rebuilt — the strongest alignment with AEBA's agenda.
Recommendation
EO Status
Comment
Beneficial Ownership Disclosure
EO Section 2(a)(iii) requires ownership and beneficial-ownership disclosures.
National Importer Registry
EO Section 2(e) updates the IOR registry and creates risk-based tiers.
Importer Financial Accountability
Requires domestic assets, increased bonding, and stronger financial-responsibility requirements.
Non-Resident Importer Reform
One of the strongest portions of the EO. Foreign-IOR restrictions are directly addressed.
Foreign IOR Restrictions
Foreign IORs prohibited from informal entry and subject to enhanced requirements.
Good Standing Requirement for Importers
EO creates a CBP “Good Standing” requirement.
Enhanced Vetting of Import Participants
Covers importers, brokers, freight forwarders, custodians, and affiliates.
Customs Bond Reform
One of the strongest alignments.
Increased Enforcement Audits
Explicitly included.
Forced Labor Enforcement
Explicit priority established.
Transshipment Enforcement
Explicit priority established.
Maximum Penalties
EO significantly strengthens penalties.
Elimination of Mitigation for Repeat Offenders
Strong enforcement provision.
Enforcement Transparency Reports
EO requires annual enforcement reporting.
Legislative Reform Package
EO Section 8 explicitly calls for legislative recommendations — the basis for this submission.
Elimination of Shell Importers
Attacks shell IOR structures via domestic-asset and ownership rules, but does not fully eliminate nominee structures.
DOJ–DHS Coordination
Enforcement coordination exists, but not the broader multi-agency framework proposed.
Platform Accountability Layer
The central gap. The EO regulates importers; it does not reach the platforms that control listings, payments, fulfillment, and marketplace access.
Recommendation
EO Status
Comment
Platform Accountability (Platform as Importer of Record)
Our central recommendation. Temu, Shein, TikTok Shop, Amazon Global, etc. remain outside direct accountability.
Platform Liability for Customs Violations
EO imposes liability on IORs, brokers, and import participants — but not on platforms.
Platform KYC Standards
Platforms remain largely self-regulated.
Seller Identity Verification (KYC)
EO adds IOR disclosures and beneficial-ownership info, but no platform-level seller verification.
Related Account Aggregation
Major gap. No mechanism to identify multiple stores operated by the same beneficial owner.
Seller-to-Import Traceability Chain
No linkage between seller, platform, warehouse, delivery provider, and payment flow.
Tax & Funds-Flow Accountability
Outside the EO's customs scope — but the income-tax measure is actionable now by executive authority, with no new legislation.
Recommendation
EO Status
Comment
Foreign Seller Tax Enforcement
EO focuses on customs, not tax compliance. Reachable now under IRC §864(b), the TCJA, and Wayfair.
Marketplace Tax Withholding
IRS / Treasury provisions absent.
Funds-Flow Monitoring
No payment-flow accountability for remittances to foreign sellers.
Logistics & Warehousing Oversight
Foreign-linked fulfillment and last-mile networks operating inside the U.S. remain almost entirely outside any transparency requirement.
Recommendation
EO Status
Comment
Foreign-Linked Logistics Network Registry
A major national-security concern remains untouched.
Warehouse Registry
Significant gap.
Warehouse Transparency Requirements
No reporting requirements for fulfillment centers.
Last-Mile Delivery Transparency
No mention of UniUni, GOFO, CIRRO-type networks.
Infrastructure Oversight Framework
Not included.
Data Integration & Risk Analytics
The EO does not connect the enforcement data that already exists, or build the analytics to act on it at scale.
Recommendation
EO Status
Comment
National E-Commerce Data Hub
No integrated CBP / IRS / FTC / DOJ / CPSC data-sharing platform.
Declared Value vs. Retail Price Analytics
One of our strongest proposals remains absent.
AI Risk Scoring for Undervaluation
No mention in the EO.
Price Parity Enforcement Model
Not included.
Interagency Data Sharing
Still absent.
Congressional Reporting
EO requires reporting to the President, not to Congress.
Supply Chain & Product Safety
The EO references product safety and supply-chain information, but stops short of an end-to-end accountability chain.
Recommendation
EO Status
Comment
Advanced Supply Chain Disclosure
Requires additional supply-chain information, but not comprehensive end-to-end visibility.
Product Safety Accountability Chain
References product safety but does not create an accountability chain.
Factory Certification Program
Not included.
Consumer Origin Disclosure
No point-of-sale transparency.
End-to-End Shipment Traceability
Not addressed.
The gaps are the roadmap.
AEBA’s Section 8 recommendations address the unaddressed: platform accountability, supply-chain transparency, logistics oversight, tax and financial accountability, and scalable enforcement through data integration.