
Who is the Importer of Record: Security Interests and the Right to Act As IOR
By: Gavin Andersen, Law Clerk, LCB and Adrienne Braumiller, Founding Partner, Braumiller Law Group Last June (2023), in response to a ruling request from Your Special

By: Gavin Andersen, Law Clerk, LCB and Adrienne Braumiller, Founding Partner, Braumiller Law Group Last June (2023), in response to a ruling request from Your Special

At the core of the definition, a Parallel import is a non-counterfeit product imported from another country without the permission of the intellectual property owner. They are also goods that are not authorized for importation into the U.S. It’s a global phenomenon, a very grey area, and their presence varies across different parts of the globe.

One of the most important requirements for importing goods into Mexico is to be registered as an importer under the Mexican importer’s registry. There are 2 types of registries for importers, one is for general importers (Padron de Importadores), and the other is for importers of specific industry sectors (Padron the Importadores de Sectores Especificos) which may import goods identified by the MX tariff code (i.e. chemical products, firearms, cigars, footwear, textiles, alcohol, hydrocarbons, steel, automotive, etc.). Generally, these 2 registries are lists with information of individuals and entities authorized to bring goods into Mexico.

Consider this scenario: a client faced the challenge of deferring duty payments while managing a significant volume of imports destined for re-exportation from the U.S. Initially considering duty drawbacks, which proved unsuitable for their specific needs, we turned our attention to bonded warehouses and free trade zones. This scenario is not uncommon in the trade world and highlights a critical decision point for many businesses: choosing between a bonded warehouse and a Foreign Trade Zone (FTZ).

The First Sale Rule applies in circumstances such as the example above. A US company places an order with a middleman in the US. The middleman in turn subcontracts to a foreign supplier. The supplier then ships the product either to the middleman or to the original US company that placed the order, meaning either could be the importer of record. The entered value could be the amount on the original purchase order or the price paid by the middleman to the foreign supplier.

The world of cryptocurrencies on blockchains and the world of traditional assets in markets have often stood in stark contrast to one another since Bitcoin’s creation in 2008. The lack of a reliable bridge between these two worlds has limited the impact of cryptocurrencies on assets in the real-world outside of on-chain speculation and prevented adoption of the benefits that blockchain technologies can bring to real world processes.

President elect Lai Ching-te’s victory in Taipei ignited tensions across the Taiwan strait and now the geopolitical field waits to see if China will kick off World War Three. I’m only slightly joking, but Beijing has exerted diplomatic pressure on nations maintaining close ties with the island in the past and Taiwan’s decision to remain a democracy will no doubt ramp up China’s reunification process in the coming months. But how will that affect trade relations?

In the complex world of international trade compliance, few people possess the expertise, dedication and problem-solving skills that Brad Menard, President of Braumiller Consulting Group, brings to his clients.

In recent years, the global spotlight has illuminated the grave concerns surrounding human rights violations within China’s Xinjiang region, particularly those impacting the Uyghur population. The Uyghur Forced Labor Prevention Act (UFLPA) stands as a pivotal piece of legislation designed to address these concerns and to ensure that products imported into the United States are devoid of forced labor originating from the Xinjiang region.

The implementation of trade policies in what many consider acts of protectionism and manipulation are the norm, and of course China and the U.S. are a prime example. Solutions include nearshoring, reshoring, and protectionism. It’s complicated, so for the purpose of this article, let’s stick with nearshoring.

A sweeping new White House Executive Order is set to once again shake up global supply chains by requiring a historic overhaul of the U.S. Importer of Record (IOR) framework. It lays out raising penalty floors, and tightening disclosure rules for everyone bringing goods into the United States, among other things.

“Origin Engineering” refers to modifying the sourcing of essential product inputs or relocating key manufacturing processes from countries subject to higher tariff rates to jurisdictions with more favorable trade treatment. It is one of the most effective tools available to importers navigating elevated tariff exposure.

Mexico’s customs and foreign trade legal framework has evolved toward a stricter and more controlled compliance model.

On June 3, 2026, President Trump issued Executive Order 14411, “Strengthening Customs Enforcement,” directing the Department of Homeland Security and U.S. Customs and Border Protection to tighten importer eligibility, increase disclosure obligations, and expand enforcement measures across the U.S. import system.

Yes, regarding this particular topic I am immediately surrounded by all of those external voices, even internal, telling me of how ridiculous it would be for the US to follow through and pull out of the USMCA. My response of course is noting that I probably wouldn’t have given the topic a second thought had the President of the United States not mentioned that this was a consideration regarding the upcoming July 2026 USMCA review.

On June 15, 2026, the U.S. Supreme Court denied a petition for a writ of certiorari in the case of HMTX Industries LLC v. United States. The petition came in response to the Federal Circuit’s decision to uphold use of tariffs against China under Lists 3 and 4A of Section 301 during the first Trump Administration.

After the U.S. Supreme Court struck down President Trump’s IEEPA tariffs as unconstitutional in February 2026, the Court tasked the U.S. Court of International Trade (CIT) with developing refund procedures for importers who paid IEEPA tariffs.

On June 2, 2026, the Office of the U.S. Trade Representative (USTR) released its report on Section 301 investigations into the practices of sixty trade partners’ economies with regard to forced labor prohibitions.

President Trump signed the new Executive Order “Strengthening Customs Enforcement.” This new order from the administration tackles different administrative priorities related to customs: Customs Reform and Combatting Customs Fraud. The order-related fact sheet goes into detail about how the Executive Order addresses these objectives and how this will affect importers moving forward.

The outcome of this customs fraud criminal investigation case highlights significant compliance risks for importers, particularly in the areas of classification, documentation, and internal controls.