CBP to Verify Importer of Record Information on Form 5106
CBP announced it is executing enhanced enforcement procedures to verify the accuracy of importer of record information provided on CBP Form 5106, and importers of record or their brokers must submit complete and accurate information by September 18 to avoid consequences. The initiative follows the
On March 31, 2026, the Office of Foreign Assets Control (“OFAC”) issued an advisory (the “Advisory”) regarding sham transactions and their use in evading US sanctions. OFAC described sham transactions as occurring when “blocked persons, often operating through proxies or other intermediaries, effectuate transfers or establish arrangements that conceal–rather than genuinely extinguish–a continuing interest in property.”