
Mark Tallo
Managing Partner at Sandler, Travis & Rosenberg, P.A., a Washington, D.C.-based international trade and customs attorney and guest on the Two Minutes in Trade podcast.
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Sep 18, 2026
Two Minutes in Trade - The Form Before the Storm: Why CBP Form 5106 Matters More Than Ever
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0:09speaker_0ANNOUNCER
For a comprehensive background on the issues discussed today, please visit strtrade.com.

Mark TalloGUEST
It's Friday, September 18th, 2026, and I'm Mark Tallo, a partner at Sandler, Travis and Rosenberg.

Mark TalloGUEST
Today, I wanted to highlight an important customs compliance development that may be flying a bit under the radar.

Mark TalloGUEST
And this is CBP's recent efforts to clean up its list of active importer of record or IOR numbers.

Mark TalloGUEST
CBP has announced that it's stepping up verification of information submitted on CBP Form 5106, and this is the form used to establish our update and importer of record account.

Mark TalloGUEST
This effort is part of a broader customs enforcement initiative focused on improving data integrity and accountability in the import process and stems from the President's Executive Order on customs enforcement issued earlier this year.

Mark TalloGUEST
Now, most importers view Form 5106 as a routine onboarding document, and it asks for basic information such as the company's name, tax identification number, address, phone number, and email.