IEEPA Refund for Non-Resident Importers: The ACH Barrier and How to Get Around It

TL;DR — Non-resident importers can file CAPE and get declarations accepted. The problem comes at payment: CBP requires a NACHA-compliant US bank account, and there are no paper checks. If you don't have US banking, your refund will sit in a hold indefinitely. The two practical paths are Form 4811 (designate a US-based party to receive on your behalf) or opening a US business bank account before your Refund Date arrives.

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The problem NRIs hit that most guides don't mention

Most CAPE guidance is written for US-based importers with existing ACH infrastructure. For foreign companies that imported as Importer of Record — Canadian manufacturers, Hong Kong trading companies, European brands with US distribution — the process looks the same up front and breaks at the last step.

You can file CAPE. Your declaration can be accepted. Your entries can reliquidate. A Refund Date can appear in ES-003. And then nothing arrives, because CBP's payment system requires a NACHA-compliant US bank account, and you don't have one.

Baker Tilly described this directly in their CAPE guidance: ACH payments are tied to ACE accounts with valid US banking information, and for non-resident importers without US banking infrastructure in place, "even approved claims may face delays at the point of payment."

CBP stopped issuing paper checks for all refunds on February 6, 2026. There is no fallback. If ACH can't execute, the money sits in a hold.

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What "NACHA-compliant US bank account" actually means

ACH (Automated Clearing House) is a US domestic payment network governed by NACHA, the National Automated Clearinghouse Association. To receive ACH payments, you need a bank account held at a US financial institution that participates in the NACHA network.

This means:

• A foreign bank account does not qualify, even if the bank has US operations
• A US dollar account held at a foreign bank does not qualify
• The account must be at a US-chartered institution or a US branch of a foreign bank that is a NACHA member
• The account must be registered in ACE through the ACH Refund Authorization tab in your Importer sub-account

If you already have a US entity with a US bank account — even if you operate primarily offshore — that account can be used as long as it's registered in ACE.

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Path 1: Form 4811 (designate a US-based party to receive on your behalf)

The most common solution for NRIs is to designate a US-based party — typically your customs broker, freight forwarder, or US-based agent — to receive the refund on your behalf. CBP calls this a "notify party" designation, and it's done via CBP Form 4811 (Special Address Notification).

How it works:

1. Your US-based broker or agent agrees to act as notify party for your refund
2. You complete CBP Form 4811 designating them as the notify party for your IOR
3. The broker/agent has their own ACE account and ACH enrollment in place
4. CBP issues the ACH payment to the broker/agent's account
5. They transfer the funds to you under whatever arrangement you've agreed on

Form 4811 is a standard CBP form that has been used for this purpose well before CAPE. It is not CAPE-specific.

What to confirm with your broker before using this path:

• They are willing to act as Form 4811 notify party for IEEPA refunds (not all brokers do this)
• They have ACH enrollment active in their ACE account for refund receipt
• You have a written agreement on how and when they will transfer funds to you, including their fee if any
• They understand that the full refund — including interest — will arrive in their account before being passed through to you

Timing note: Once you file Form 4811, CBP updates their records. This needs to be in place before your refund processes, not after. If a payment already rejected because no ACH was on file, you can still fix it — update the Form 4811 designation and contact IEEPARefunds@cbp.dhs.gov to re-initiate the transfer.

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Path 2: Open a US business bank account

If you operate as a foreign company with regular US import activity, opening a US business bank account is the more durable solution. It gives you direct control over the refund without a pass-through arrangement with your broker.

US banking for foreign businesses has gotten significantly easier in recent years. Several options exist depending on your structure:

If you have a US legal entity (LLC, C-Corp, branch office): Standard US business bank accounts are available through major US banks and online-first banks. This is the straightforward path.

If you operate as a pure foreign entity without US incorporation: Some US banks and online business banking platforms will open accounts for foreign companies, typically requiring a US EIN, certificate of incorporation, and proof of business activity. Requirements vary significantly by institution.

Before opening an account specifically to receive a CAPE refund, confirm with the institution that the account will support NACHA ACH receipt transactions. Most standard US business checking accounts do, but it's worth verifying before you complete ACE enrollment.

Once the account is open, enroll it in ACE through the ACH Refund Authorization tab in your Importer sub-account. This enrollment is separate from any ACH setup you may have for paying duties.

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ACE account setup for NRIs

Getting an ACE Portal account as a non-resident importer uses the same process as a US-based importer — submit Form 5106 (Importer ID Input Record) to CBP. The form can be submitted by your licensed customs broker on your behalf.

For NRIs, processing can take longer than the standard 30-day window, particularly if CBP needs to verify importer of record identity without a US address or EIN. Some NRIs use a CBP-assigned importer number instead of an EIN — confirm which identifier was used on your original entry summaries, as that's what needs to match your ACE account.

If your customs broker filed all your entries, you may not have your own ACE account at all. Your broker has theirs. Without your own account, you cannot enroll ACH refund information directly — you're dependent on the Form 4811 path unless you create your own account.

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If your refund is already in a hold

If your CAPE declaration has been accepted, a Refund Date has come and gone, and nothing has arrived — check REV-613 in ACE first. If your IOR appears in that report, CBP attempted payment and the ACH rejected. The funds are in a hold, not lost.

To recover from this state:

1. Set up either the Form 4811 designee path or a US bank account in your ACE Importer sub-account
2. Verify the ACH Refund Authorization tab shows the correct account or designee
3. Email IEEPARefunds@cbp.dhs.gov with your CAPE claim number and a brief note that you've updated your ACH enrollment. Ask them to re-initiate the transfer.

CBP does not automatically retry rejected payments. You need to prompt them after fixing the enrollment.

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One thing to do now regardless of which path you choose

File your CAPE declaration as soon as your ACE account is ready — don't wait until the ACH question is resolved. The 80-day eligibility window keeps running. An accepted declaration with a payment on hold is much better than entries that aged out of Phase 1 because you were waiting on banking.

File now. Resolve the ACH path before your Refund Date arrives.

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Frequently asked questions

I'm a Canadian company and we imported as IOR. Can we file CAPE at all? Yes. Eligibility to file CAPE is based on being the Importer of Record on the entry, not on where your company is based. The barrier is payment, not filing. File the declaration, then resolve the ACH path before your Refund Date arrives.

Can my US customs broker receive the refund on my behalf? Yes, through Form 4811. Your broker needs to agree to act as notify party, have ACH enrollment in their own ACE account, and you need a written arrangement for how they pass the funds to you. Not all brokers offer this service — confirm before assuming.

Does Form 4811 work for any broker, or does it have to be the one who filed my entries? Form 4811 designates a notify party for the refund payment only — it is separate from who filed the CAPE declaration. Your filing broker and your Form 4811 notify party can be different parties. The notify party just needs to be CBP-recognized with valid ACH enrollment.

We have a US EIN but no US bank account. Can we get the refund? Having an EIN gets you an ACE account, but the refund requires a US bank account with ACH enrollment. An EIN alone doesn't unlock payment. You need the bank account registered in the ACH Refund Authorization tab.

I paid duties through my broker's account — shouldn't the refund go back there? No. Duty payments and refunds are handled through different mechanisms. How you paid duties has no bearing on where CBP sends the refund. The refund goes to whichever account is registered in ACE under your IOR's ACH Refund Authorization tab, or to a Form 4811 designee.

Is there any way to get the refund sent to a foreign account? No. ACH is a US-only payment network. There is no mechanism for CBP to send an ACH refund to a non-US account. The only paths are a US bank account enrolled in ACE, or a Form 4811 designee with their own US bank account in ACE.

We're a Hong Kong company. Can we open a US bank account fast enough to catch Phase 1? Possibly, depending on your structure. If you already have a US entity (LLC or C-Corp), a US business bank account can often be opened within days online. If you need to first incorporate in the US, that adds time. The faster path for most pure foreign entities is Form 4811 with your existing US broker. File the declaration now. The 80-day window doesn't wait.

If we use Form 4811 and the broker receives our refund, what's our recourse if they don't pay us? That's a contractual matter between you and your broker, not a CBP matter. Once CBP pays the notify party, CBP's obligation is complete. Get the pass-through terms in writing — amount, timeline, and fee — before filing the Form 4811.