91 billion.

In addition, Executive Order 14411, “Strengthening Customs Enforcement,” signed on June 3, 2026, has a major impact on trade in the U.S. and worldwide. Here is a summary of each key topic discussed at the summit:

Forced Labor

It was reaffirmed that CBP will seek broader reach to evaluate the supply chains of any importer of record (IOR), whether CTPAT or not. All manufacturing processes of the imported product, as well as the origin of raw materials, must be clearly identified. This responsibility will fall mainly on importers; however, manufacturers’ participation will be vital to provide visibility, trace the origin of raw materials, and have agreements and policies to prevent forced labor at any point in the chain that produces the final product.

Compliance

CTPAT made its position clear: being a CBP partner carries the commitment not to engage in transshipping, fraud, tariff evasion or undervaluation. Detection of any of these practices can lead to cancellation of CTPAT and suspension of MID and/or IOR registrations.

The summit made the goal very clear: OEA and CTPAT are getting closer to alignment on compliance and customs management. We consider it prudent for importers already certified in CTPAT to start seeking integration into the CTPAT Trade Compliance program.

Cabotage

This topic was considered very sensitive and was addressed only through a question in the Q&A session. We know the major impact ICE operations have had at ports of entry, questioning cross-border drivers’ movements and looking for any deviation from U.S. cabotage rules. The summit’s message was that these incidents must be reported to CTPAT specialists or officers and, depending on the type of incident, may be subject to corrective action and even suspension of the CTPAT account.

Artificial Intelligence

CBP is no exception in using artificial intelligence. The amount of data DHS handles and the platforms available to CBP allow more precise and objective inspections. At the summit, they discussed the positive impact it has had on applying and monitoring their rules much more effectively.

Participants were encouraged to use these tools as well to prepare and update their risk assessments and to identify vulnerabilities in their supply chains, for both contamination and forced labor, always with human review and approval.

USDA and Wood Pallets

A criterion often taken for granted in CTPAT now has stronger enforcement. Since the Executive Order was signed, USDA inspections of wood pallet treatment compliance have increased considerably (around 300%).

We were reminded to treat pallet suppliers as critical business partners, with annual assessments and visits. USDA fines are calculated on the value of the goods and can reach up to 100% of the shipment value. We therefore recommend:

• Strengthening pallet inspection practices.
• Training receiving and shipping staff to check ISPM 15 compliance.
• Reviewing policies and procedures for these incidents, including how to respond to a CBP EAN notice.

Foreign IORs and U.S. Customs Brokers

Foreign importers of record are increasingly rare and, with the Executive Order, most will likely disappear and choose to form an LLC or corporation in the U.S. If you use a foreign IOR, the order requires CTPAT certification and/or working with a validated CTPAT customs broker. This will increase the administrative burden on customs brokers, who will very likely not want to take on the risk of working with foreign IORs.

Cybersecurity: AI-Driven Attacks

A specialist discussed the risks and vulnerabilities DHS/CBP itself faces daily: it receives countless cyberattacks aimed at destabilizing supply chains and infrastructure. He stressed the importance of having contingency and business continuity plans in case your company is involved in a cybersecurity incident.

High-Risk Zones in Mexico: CTPAT Limitations

Since 2024, the U.S. Department of State and Embassy have drawn a risk map of Mexico that has caused some companies pending validation (on-site audit) to have their process postponed or even withdraw their CTPAT application until the map is updated.

Companies validated before 2024 that are located within the risk map will have virtual revalidations. New AI tools in the portal are expected by mid-to-late 2027 to speed up reviews and possibly open the door to virtual validations for first-time applicants.

Conclusions

Many topics were covered that we have been learning at a forced pace, as changes and decrees have required us to react and update our processes and continuity plans day by day, and I expect this to continue. In 2027, CTPAT will mark 25 years since its founding, and the program is expected to become an increasingly indispensable pillar for the industry and for ensuring the continuity of trade with the U.S.

Want to review how these changes affect you? Contact us or message us on WhatsApp at 686 543 1017.

This newsletter summarizes what was presented at the 2026 Trade and Cargo Security Summit and is provided for informational purposes only. It does not constitute legal advice and does not replace official guidance from CBP or other agencies. We recommend reviewing current regulations and consulting your legal advisor as needed.

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