On June 3, 2026, Executive Order (EO) 14411 was signed, establishing the foundation for the future of customs enforcement. It allows Customs and Border Protection (CBP) to apply stricter import requirements that will promote enhanced transparency and increased importer accountability. Just over two months later on August 13, the White House released a report titled The Great Transshipment Scam: Rise, Scope, and Costs.
With EO 14411 as its foundation, the transshipment report aims to address the alleged negative impacts of illegal transshipment involving Chinese goods. The report identifies key players in what’s referred to as the “Shadow Transshipment Network” and calls for the creation of an AI-enabled CBP “Detective Border”.
EO 14411 is a comprehensive customs-enforcement order. Provisions within the EO include stricter Importer of Record (IOR) requirements, foreign IOR restrictions, stronger enforcement and penalties, and forced-labor prioritization.
The EO also addresses transshipments in multiple places. The most direct mention is in Section 4(b). This section directs the Secretary of the Department of Homeland Security (DHS) and the Attorney General to prioritize the enforcement of illegal transshipments.
Several other parts of EO 14411 could also make illegal transshipment more difficult, even though they are not exclusively anti-transshipment measures.
For example, EO 14411 strengthens customs enforcement by addressing:
Importer accountability
Bonding
Domestic assets
Ownership disclosure
Business affiliations
Good-standing requirements
Penalties
Trade transparency
Each provision gives CBP more information they can use to identify origin claims or attempts to conceal who actually produced merchandise. While transshipments are only one of many problems addressed by EO 14411, The Great Transshipment Scam: Rise, Scope, and Costs report focuses on it entirely.
However, the report doesn’t enact new regulatory requirements for importers. It serves as an analytical and policy document that signals potential enforcement and legislative changes.
Essentially, EO 14411 provides a regulatory foundation for future customs-enforcement measures consistent with the priorities outlined in the transshipment report.
Heightened Scrutiny of Third-Country Sourcing
The transshipment report claims the existence of a so-called “Shadow Transshipment Network.” This network comprises countries divided into three tiers, with each tier representing a different level or type of alleged transshipment risk. This graphic shows how they’re organized.
Tier 1 comprises nations where illegal transshipments occur within largely legitimate trade flows. In Tier 2 nations, there are significant illegal transshipment volumes that are deeply integrated into China-linked supply chains. Finally, Tier 3 nations are countries that are targeted for China-linked rerouting. These countries may offer characteristics that facilitate rerouting, including low-cost labor, bonded warehousing, and free-port or border access.
The network is large and complex, which makes detecting transshipments extremely difficult. What’s needed to counter it is a network-based approach. The White House proposes an AI-enabled approach called “Detective Border”.
AI-Enabled CBP Detective Border
The transshipment report released by the White House outlines an AI-enabled “Detective Border”. The report presents it as a potential tool for combatting the Shadow Transhipment Network. This AI will integrate various data points to improve CBP’s ability to detect potential illegal transshipments and identify high-risk imports.
The analytical tools include:
Shipment data
Routing histories
Product classifications
Ownership relationships
Production-capacity indicators
Based on the report, the White House believes that Detective Border could significantly expand CBP’s analytical capabilities. The AI’s algorithms can compare declared origins, routing histories, and component content against expected patterns. With access to so much information, it can reveal inconsistencies that no human could catch at such a large scale.
The abilities of Detective Border are expected to boost the effectiveness of CBP’s existing risk-based targeting models. Its insights will direct CBP officers to offenders, while increasing the efficiency and precision of every enforcement action.
EO 14411 also complements Detective Border by serving as an institutional backbone. The AI identifies anomalous importing activity that’s indicative of transshipments like unusual routing patterns and false-origin claims. Meanwhile, EO 14411 strengthens CBP’s ability to respond to the signals that Detective Border uncovers.
What Importers Can Do to Prepare
EO 14411 is laying the groundwork for tougher customs enforcement, which means more regulatory challenges for importers. If Detective Border does come online in the future, it will only increase CBP’s ability to discover discrepancies, whether they’re transshipment-related or not.
As someone who’s worked for the same 3PL for nearly five years, I can say with confidence that importing is a task that should be undertaken with the utmost care. Importers should always assume that CBP has more data, more tools to cross-check that data, and stronger mechanisms for acting on discrepancies.
Practical steps I recommend importers should follow include:
Audit IOR Information
Strengthen country-of-origin documentation
Map supply chains beyond immediate suppliers
Review suppliers in higher-risk transshipment corridors
Look for Inconsistencies before CBP finds them
Prepare for expanded IOR disclosure and financial requirements
Coordinate with customs brokers and trade counsel
The common thread among these preparations is greater supply chain visibility. EO 14411 strengthens importer accountability and the transshipment report proposes more sophisticated methods for detecting suspicious trade activity. That means importers will need greater insight into where their goods originate, who handles them, and how they move through the supply chain.
Maintaining accurate records and identifying discrepancies before goods reach the border can help importers substantiate legitimate transactions if they face greater scrutiny from CBP.
