Electronic Customs Refunds, How Importers Should Prepare Their ACE Banking Information

Introduction

Electronic customs refunds are no longer simply a convenience. They are becoming a core component of federal payment administration and importer financial compliance.

Executive Order 14247, Modernizing Payments To and From America’s Bank Account, directed the Department of the Treasury to cease issuing paper checks for federal disbursements, to the extent permitted by law, effective September 30, 2025. The order includes refunds and directs federal agencies to transition recipients to electronic payment methods. 

U.S. Customs and Border Protection subsequently modernized its Automated Clearing House refund enrollment process through the Automated Commercial Environment Portal. Effective February 6, 2026, corporations and individual payees with an ACE Portal account are required to manage their electronic refund banking information through the ACH Refund Authorization tab. 

This transition is especially important for importers expecting refunds from liquidations, protests, post summary corrections, drawback claims, reconciliation, duty overpayments, court directed refund programs, or other CBP administrative actions.

Incorrect banking information, inadequate ACE access, or unclear internal responsibility can delay access to funds and create avoidable accounting and reconciliation problems.

Regulatory and Policy Context

Executive Order 14247

Executive Order 14247 established a federal policy favoring electronic payments over paper checks. The policy is intended to reduce fraud exposure, improve payment efficiency, lower administrative costs, and increase the security of federal disbursements.

The order directed the Treasury Department to cease issuing paper checks for federal disbursements effective September 30, 2025, except where a limited exception applies. Federal agencies were instructed to enroll recipients in electronic funds transfer methods, including direct deposit and other approved electronic payment options. 

The transition does not mean that every importer will automatically receive a refund merely by entering banking information. The importer must still be legally entitled to the refund under the applicable customs law, liquidation decision, protest determination, drawback claim, reconciliation filing, or other authorized process.

CBP’s Electronic Refund Rule

CBP’s electronic refund requirements were implemented following the federal government’s broader transition away from paper checks. The electronic refunds rule requires refund recipients to receive qualifying payments electronically, subject to applicable exceptions and implementation procedures. 

CBP now provides an electronic enrollment process within the ACE Portal. Trade Account Owners with an associated importer account view can add, review, and update U.S. banking information through the ACH Refund Authorization tab. 

The Role of the ACE Portal

ACE is CBP’s primary electronic trade processing environment. For refund enrollment, the importer generally needs:

1. An active ACE Portal account.
2. Access to the correct Importer subaccount.
3. A properly designated Trade Account Owner, or another user with the appropriate ACE permissions.
4. An importer account correctly associated with the applicable Importer of Record number.
5. Valid U.S. banking information.
6. Internal authorization to provide and maintain the company’s banking information.

An importer that does not have the appropriate Importer subaccount view may be unable to access the ACH Refund Authorization tab until the ACE account structure and permissions are corrected.

What CBP Expects Importers to Understand

1. Refund Enrollment Is Managed at the Importer Account Level

Importers should confirm that their ACE Portal account is connected to the correct Importer of Record number.

Many organizations operate under more than one importer number. These may include:

1. An Employer Identification Number.
2. An Employer Identification Number with an importer suffix.
3. A Social Security Number based importer number.
4. A CBP assigned importer number.
5. Separate importer numbers for related corporate entities.

Banking information should be associated with the correct legal entity and importer account. A mismatch between the refund recipient, Importer of Record number, and bank account owner may create payment rejection, verification, or reconciliation problems.

2. The Bank Account Should Belong to the Refund Recipient

Federal electronic payments are generally expected to be deposited into an account belonging to the designated payment recipient. Treasury electronic payment rules are designed to direct federal payments to the recipient’s account at a financial institution. 

Importers should therefore avoid entering:

1. An employee’s personal bank account.
2. A customs broker’s operating account.
3. A freight forwarder’s account.
4. An unrelated affiliate’s bank account.
5. A former corporate account that has been closed.
6. A temporary account that is not controlled by the importer.

A customs broker may assist with ACE procedures, refund research, and account administration. However, the importer should retain control over the selection, authorization, and verification of the bank account receiving its customs refunds.

3. Banking Information Must Be Accurate

ACH enrollment normally requires information such as:

1. The financial institution’s routing transit number.
2. The bank account number.
3. The account type.
4. The account holder or company information.
5. Confirmation that the account can receive ACH credits.

A single incorrect digit may cause a payment to be rejected or misdirected. Importers should not rely solely on information copied from an old check, spreadsheet, email, or prior payment instruction.

The banking information should be independently confirmed with the company’s treasury department or financial institution.

4. ACE Access Must Be Properly Controlled

Bank account information is sensitive financial data. Access to the ACH Refund Authorization function should be limited to authorized personnel.

Importers should determine:

1. Who serves as the Trade Account Owner.
2. Which users can view importer information.
3. Which users can add or modify refund banking information.
4. Who must approve a banking change.
5. How access is removed when an employee leaves or changes responsibilities.
6. How the company documents banking changes.

ACE access should not remain assigned to former employees, outside consultants, or service providers that no longer require access.

5. Electronic Enrollment Does Not Replace Refund Monitoring

Entering banking information does not replace the need to monitor refund eligibility and payment status.

Importers should continue reviewing:

1. Entry liquidation activity.
2. Protest decisions.
3. Post summary correction results.
4. Reconciliation liquidations.
5. Drawback claim status.
6. Duty refund program notices.
7. Treasury payment records.
8. ACE financial reports.
9. Refund amounts received in the bank account.
10. Differences between expected and actual refunds.

CBP states that ACE reports allow users to review account transactions and financial information. These reports can support refund reconciliation and exception review. 

Why the Issue Is Particularly Important in 2026

The need for accurate ACE banking information has become more significant because CBP is administering substantial electronic refund activity through modernized processes.

For example, CBP’s current guidance regarding International Emergency Economic Powers Act duty refunds instructs importers to establish the Importer subaccount in the ACE Portal and provide refund banking information. CBP also introduced procedures through which importers and customs brokers may submit certain refund requests electronically. 

Importers should not assume that their customs broker’s ACE access automatically completes the importer’s banking enrollment. The Importer of Record should confirm that its own ACE account, permissions, importer number, and refund banking information are properly established.

Common Compliance Gaps

No Active ACE Portal Account

Some importers depend entirely on their customs broker for entry filing and have never established their own ACE Portal account.

This limits the importer’s ability to:

1. Manage electronic refund enrollment.
2. Review importer account information.
3. Run compliance reports.
4. monitor financial activity.
5. Verify importer numbers and relationships.
6. Maintain direct oversight of CBP account data.

Missing Importer Subaccount

An organization may have an ACE Portal account but still lack access to the correct Importer subaccount.

The importer should verify that the company’s Importer of Record number appears in the account and that the authorized user can access the ACH Refund Authorization tab.

Incorrect Importer Number

A company may enter banking information under one importer suffix while refunds are associated with another importer number.

This is particularly risky after:

1. Corporate reorganizations.
2. Acquisitions.
3. Employer Identification Number changes.
4. Changes in legal entity structure.
5. Importer number suffix creation.
6. Changes to CBP Form 5106 information.

Each importer number should be reviewed separately.

Use of Outdated Banking Information

Refunds may be disrupted when a company changes banks, closes an account, completes a merger, or restructures its treasury operations without updating ACE.

Banking changes should be incorporated into the importer’s customs compliance change management process.

Excessive User Access

Giving too many users permission to modify refund banking information increases the risk of unauthorized or accidental changes.

Access should be restricted according to job responsibilities and reviewed periodically.

Weak Internal Verification

A bank routing number or account number supplied through an ordinary email may be incorrect or fraudulent.

Importers should use a controlled verification process, particularly when banking instructions change. Verification may include confirmation through a known treasury contact, a bank letter, an established internal financial system, or direct confirmation with the financial institution.

Failure to Reconcile Refunds

An electronic deposit may reach the importer’s bank account without enough internal detail for the accounting department to immediately identify the related entries.

1. Misapply the refund.
2. Fail to allocate funds to the correct business unit.
3. Miss an incorrect refund amount.
4. Overlook a Treasury offset.
5. Fail to account for broker advances or duty receivables.
6. Leave customs refund receivables open unnecessarily.

Practical Steps for Importers

Step 1. Identify Every Active Importer of Record Number

Prepare a controlled list of all importer numbers used by the organization.

For each number, record:

1. The legal entity name.
2. The Employer Identification Number.
3. The importer suffix, when applicable.
4. The CBP assigned importer number, when applicable.
5. The business unit using the number.
6. The ACE account association.
7. Whether the number remains active.
8. The bank account that should receive refunds.

This review can prevent refunds from being connected to an inactive entity or incorrect banking profile.

Step 2. Confirm the ACE Portal Account Structure

The importer should confirm that:

1. The ACE Top Account is active.
2. The Trade Account Owner is a current authorized employee.
3. The correct Importer subaccount is visible.
4. The importer number is properly associated.
5. The ACH Refund Authorization tab is available.
6. The appropriate users have access.
7. Former users have been removed.

CBP provides guidance for managing ACE Secure Data Portal accounts, including procedures for correcting account access and submitting certain account requests. 

Step 3. Obtain Verified Banking Information

The company’s finance or treasury department should provide verified information for a U.S. bank account capable of receiving ACH credits.

The verification package should include:

1. Legal name of the account holder.
2. Bank name.
3. Routing transit number.
4. Account number.
5. Account type.
6. Confirmation that the account accepts ACH credits.
7. Effective date of the instruction.
8. Name and title of the approving official.
9. Internal approval documentation.

Sensitive banking information should be transmitted and stored using the company’s approved security procedures.

Step 4. Establish Dual Approval

One employee should not independently request, enter, approve, and verify a banking change.

A stronger process separates responsibilities:

1. Treasury provides the banking instruction.
2. An authorized ACE user enters the information.
3. A second authorized person verifies the entry.
4. Compliance confirms the correct importer number.
5. Accounting monitors the first electronic refund.

This control reduces the risk of typographical errors, unauthorized changes, and payment fraud.

Step 5. Document the Enrollment

The importer should maintain a record showing:

1. The importer account updated.
2. The date of enrollment.
3. The person who entered the information.
4. The person who approved the information.
5. The source used to verify the routing and account numbers.
6. Confirmation of the account type.
7. Any ACE confirmation or status information.
8. Subsequent changes or corrections.

The record should not expose banking information to employees who do not require access.

Step 6. Test the Reconciliation Process

After the first electronic refund is received, the importer should determine whether the finance team can connect the deposit to:

1. The CBP payment information.
2. The importer number.
3. The relevant entry or claim.
4. The refund authorization.
5. The expected duty amount.
6. Any interest included.
7. Any Treasury offset or reduction.

Treasury payments may be processed electronically through the ACH network, which deposits funds directly into financial institution accounts. 

Step 7. Monitor ACE and Bank Activity

Importers should establish a recurring review of:

1. ACE refund authorization status.
2. Importer account access.
3. Changes to banking information.
4. Expected refund amounts.
5. Refund deposits received.
6. Rejected or returned payments.
7. Outstanding refund receivables.
8. CBP notices and Cargo Systems Messaging Service announcements.

The customs compliance team and accounting department should share responsibility for this review

Step 8. Include Refund Banking in Corporate Change Management

The ACE banking profile should be reviewed whenever the company experiences:

1. A merger or acquisition.
2. A legal name change.
3. A new Employer Identification Number.
4. A bank conversion.
5. An account closure.
6. A treasury department restructuring.
7. A change in Trade Account Owner.
8. Employee termination or transfer.
9. A change in importer suffix usage.
10. A change in customs broker.

Changing customs brokers does not automatically update the importer’s ACE refund banking information.

Internal Control Checklist

Importers should be able to answer yes to the following questions:

• Do we have an active ACE Portal account?
• Can we access the correct Importer subaccount?
• Is our Trade Account Owner still employed and properly authorized?
• Have we identified every importer number used by the company?
• Is the ACH Refund Authorization tab available?
• Does the refund bank account belong to the correct legal entity?
• Has the bank confirmed that the account accepts ACH credits?
• Did two authorized people verify the routing and account numbers?
• Do we maintain a record of enrollment and subsequent changes?
• Can accounting identify and reconcile an electronic CBP refund?
• Do we periodically review ACE users and permissions?
• Is ACE banking information included in our corporate change management procedures?

Broker Responsibility and Importer Oversight

A licensed customs broker can provide valuable assistance with entry history, liquidation monitoring, protest status, reconciliation, drawback activity, and refund research.

However, the Importer of Record remains responsible for maintaining appropriate control over its legal identity, ACE account, financial information, and internal accounting.

The importer should not assume that the customs broker:

1. Owns the importer’s ACE account.
2. Controls the importer’s bank account.
3. Can change banking information without authorization.
4. Receives every refund notice.
5. Can automatically reconcile Treasury deposits to the importer’s accounting records.

The strongest process involves coordination among the importer, customs broker, compliance department, treasury personnel, and accounts receivable team..

Cybersecurity Considerations

Banking information changes are a frequent target for business email compromise and payment diversion schemes.

Importers should treat any request to change ACE refund banking information as a high risk financial instruction.

Recommended controls include:

1. Multifactor authentication for ACE and corporate email accounts.
2. Verification through a known telephone number.
3. Prohibition on approving banking changes solely by email.
4. Role based access to ACE.
5. Immediate removal of former employees.
6. Periodic review of ACE user permissions.
7. Secure storage of bank confirmation documents.
8. Escalation procedures for unexpected banking changes.
9. Independent review of the first refund after a change.
10. Written incident response procedures.

A customs refund may involve a significant amount of money. The refund process should therefore receive controls comparable to vendor payment and wire transfer processes.

How S. J. Stile Associates Can Help

S. J. Stile Associates Ltd. can assist importers with the customs compliance and operational aspects of electronic refunds, including:

1. Reviewing importer numbers associated with customs transactions.
2. Identifying entries that may generate refunds.
3. Monitoring liquidation and post entry activity.
4. Assisting with post summary corrections and protests.
5. Supporting reconciliation and drawback research.
6. Providing entry level documentation for accounting reconciliation.
7. Reviewing ACE account and importer relationship issues.
8. Coordinating with the importer’s authorized compliance and finance personnel.
9. Helping importers understand current CBP refund guidance.
10. Maintaining communication regarding refund related entry activity.

Bank account selection and financial authorization should remain under the importer’s internal control. Our role is to help ensure that the customs records, importer identity, refund process, and supporting documentation are properly coordinated.

Frequently Asked Questions

Are electronic customs refunds now required?

CBP has transitioned its refund enrollment process toward electronic payment. Effective February 6, 2026, corporations and individual payees with an ACE Portal account are required to use the ACH Refund Authorization tab to manage banking information. Limited exceptions may apply under federal payment rules, but importers should prepare for electronic receipt as the standard method. 

Where does an importer enter its banking information?

The information is entered through the ACH Refund Authorization tab in the Importer subaccount view of the ACE Portal. 

Does the importer need its own ACE Portal account?

An importer that is not already enrolled for ACH refunds generally needs access to an ACE Portal account with the appropriate Importer subaccount view to authorize refund banking information. 

Can our customs broker enter the banking information?

The importer should consult current CBP permissions and account guidance. A broker may assist with the process when properly authorized and when the applicable ACE account permissions permit it. However, the importer should independently approve and verify all banking information.

Can the refund be deposited into the broker’s bank account?

As a general control principle, the refund account should belong to the legal refund recipient. Using a broker’s operating account could create ownership, authorization, accounting, and reconciliation concerns.

Can one bank account be used for multiple importer numbers?

A company may use a central corporate account where legally and operationally appropriate. However, each importer account and legal entity should be reviewed separately. The account holder name, importer identity, and internal authorization should be consistent.

What happens if the routing or account number is wrong?

The payment may be rejected, returned, delayed, or routed incorrectly. The importer should immediately verify the information in ACE and coordinate with CBP, Treasury, and its financial institution as appropriate.

Will ACH enrollment accelerate CBP’s decision on a refund claim?

No. ACH enrollment affects the method of payment. It does not determine whether a protest, drawback claim, correction, reconciliation, or other refund request will be approved.

Does ACH enrollment guarantee that a refund will not be offset?

No. A federal payment may be reduced or offset when authorized under applicable law. Importers should reconcile the expected refund against the amount actually received and investigate any difference.

How should the importer identify an electronic refund in its bank account?

The importer should compare the Treasury deposit information with ACE reports, entry data, liquidation activity, protest decisions, and internal refund receivables. Finance and customs compliance teams should establish a shared reconciliation procedure.

Should banking information be sent to the customs broker by ordinary email?

Sensitive banking information should be transmitted only through approved secure methods. Any banking change should be independently verified with a known company representative.

How often should ACE banking information be reviewed?

At least annually, and immediately following a bank change, corporate restructuring, importer number change, acquisition, employee departure, or change in ACE account administration.

Conclusion

Electronic customs refunds require more than entering a routing number and bank account number into ACE.

Importers need an active ACE account, correct importer relationships, verified banking information, restricted user permissions, documented approvals, and a reliable financial reconciliation process.

The shift to electronic refunds can improve payment speed and reduce the risks associated with paper checks. It can also create new exposure when importer numbers, account ownership, ACE permissions, or banking information are not properly controlled.

Importers expecting refunds should review their ACE account structure now, confirm the correct Importer of Record numbers, validate their banking information, and coordinate responsibilities among customs compliance, treasury, accounting, information security, and their licensed customs broker.

References

1. The White House, Executive Order 14247, Modernizing Payments To and From America’s Bank Account, March 25, 2025. 
2. Federal Register, Modernizing Payments To and From America’s Bank Account, March 28, 2025. 
3. U.S. Customs and Border Protection, ACH Refund. 
4. U.S. Customs and Border Protection, ACE Portal and ACH Refunds Frequently Asked Questions. 
5. U.S. Customs and Border Protection, ACE Portal, ACH Bank Information for Electronic Refunds. 
6. U.S. Customs and Border Protection, Electronic Refund Enrollment in the ACE Portal. 
7. U.S. Customs and Border Protection, CBP Modernizes Electronic Refund Enrollment Process. 
8. Federal Register, Electronic Refunds, January 2, 2026. 
9. U.S. Department of the Treasury, Bureau of the Fiscal Service, Direct Deposit, Electronic Funds Transfer. 
10. U.S. Department of the Treasury, Bureau of the Fiscal Service, Automated Clearing House. 
11. U.S. Customs and Border Protection, International Emergency Economic Powers Act Duty Refunds. 

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Contact S.J. Stile Associates today to learn how we can strengthen your compliance posture and streamline your supply chain.

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