IEEPA Refund for Foreign Importers With No US Bank Account

TL;DR – A foreign importer of record can file CAPE. The problem is payment: since February 6, 2026, CBP pays refunds by ACH to a US bank account. The options are a broker named as Form 4811 notify party, your own US bank account enrolled in ACE, or a paper check in hardship cases. File now and set up payment before the refund is issued. Talk to a customs attorney about your situation.

Can a foreign importer get an IEEPA refund?

Yes. The step where foreign importers get stuck is payment. Most CAPE guidance assumes a US company with a US bank account. A foreign company that was importer of record (a Canadian manufacturer, a Hong Kong trading company, a European brand) sees the same process up front.

You can file CAPE, your Declaration can be accepted, and your entries can reliquidate. Then nothing arrives, because there is no US bank account to pay.

CBP's Electronic Refunds rule, in effect since February 6, 2026, makes ACH the default for refunds. It says: "Foreign importers will need to obtain a U.S. bank account or authorize their broker to receive refunds on their behalf" (FR 2025-24171).

Waiting costs interest. Under the same rule, if CBP certifies an electronic refund within 30 days of liquidation or reliquidation but cannot send it only because you gave no banking details, no further interest accrues under 19 U.S.C. § 1505(d) (FR 2025-24171). Interest earned before that is not lost, but the refund may stop growing while it waits.

Can CBP pay a bank account outside the US?

No. ACH is a US payment network. CBP sends the refund to the bank account entered in ACE, in the ACH Refund Authorization tab of the Importer sub-account. The rule says "all applicants are required to use a U.S. bank account" (FR 2025-24171). See ACH Setup Guide.

If you already have a US company with a US bank account, that account can be enrolled. If you have no ACE account of your own because your broker filed everything, you cannot enroll a bank account yourself until you set up ACE access. See ACE Portal Setup.

Option 1: Can my broker receive the refund as 4811 notify party?

Yes. This is the route CBP's rule names: you authorize your broker to receive refunds for you. It is done with CBP Form 4811, which names a notify party.

Two conditions, both required. CBP sends a refund to a notify party only if "1) the notify party is on file in the importer's ACE profile, and 2) the notify party's importer of record (IR) number is listed in box 28 'Reference Number' of the CBP Form 7501 or its electronic equivalent" (CSMS #67648307). If only one condition is met, the refund goes to you as importer of record.

The broker needs its own ACH enrollment. If the notify party is not enrolled in ACH, "the refund will default to the importer's ACH account" (FR 2025-24171). With no US account of your own, the refund then waits.

What to agree with your broker first:

• That it will act as notify party for IEEPA refunds. Not every broker does.
• That its ACH enrollment for refunds is active in its own ACE account.
• In writing: how and when it passes the money to you, and its fee. Importers report fees for forwarding refunds.

Once CBP pays the notify party, getting the money from the broker is a matter of your contract with it, not a CBP matter. If that goes wrong, see Your Carrier or Broker Got Your IEEPA Refund.

Can a new broker be the notify party if it did not file my entries?

We found no CBP answer written for this, though importers ask it often. The second condition is the problem: the notify party's number has to be in box 28 of each entry summary. A new broker that never filed your entries is not in box 28 on them. CBP tells importers to make any Post Summary Correction before CAPE, and once an entry is in a CAPE Declaration, ACE refuses a PSC on it (CSMS #68340863; CSMS #68397097). See PSC Before CAPE. Ask your broker and CBP before you rely on this route for entries that are already filed.

Option 2: Should we open a US business bank account?

Yes, if you want the refund directly. A US account in your company's name pays you with no pass-through. Some US banks open accounts for foreign companies; what they require varies by bank. Before you open one for this, confirm it can receive ACH credits.

Once it is open, enroll it in the ACH Refund Authorization tab of your Importer sub-account in ACE. This is separate from any ACH set up for paying duties.

One importer reported on Reddit borrowing a law firm's US account for a 4% fee (r/CustomsBroker, 1uem08r, July 2026). That is a single post, not a CBP route. CBP's rule names only your own US account or your broker. Ask a customs attorney before you route a refund through anyone else's account.

Option 3: Can we get a paper check instead?

Only through a hardship waiver, and we found no report of one granted to a foreign importer. Since February 6, 2026, CBP issues no paper checks by default. The rule keeps one exception: the electronic payment requirement can be waived where it causes a hardship (31 U.S.C. § 3332(f)(2)(A); waiver process in 31 CFR 208.4). To ask for a check, write to CBP's Revenue Division at frn-achrefundsupport@cbp.dhs.gov and state which waiver ground applies to you (FR 2025-24171).

The rule does not list the grounds or say how long a decision takes. Treat it as a fallback, not a plan.

Our refund was accepted but never arrived. What now?

Check REV-613 in ACE. It shows payments rejected at ACH delivery. A rejected refund is on hold, not lost.

1. Set up one of the options above: your own US account in the ACH Refund Authorization tab, or a broker notify party that meets both conditions.
2. Check that the ACH Refund Authorization tab shows the right account.
3. Follow CBP's Replacement Refund Instructions. Questions about a rejected payment go to frn-achrefundsupport@cbp.dhs.gov.

See CAPE Refund Rejected for ACH, ACH Setup Guide and CAPE Refund Not Received.

Our entries liquidated more than 80 days ago. Does being foreign change anything?

No. Being foreign does not change the dates. CAPE Phases 1 and 2 take entries liquidated within the preceding 80 days, counted back from the day you file your Declaration (CSMS #68340863). Older entries follow the same paths as for any importer:

• Your own suit at the Court of International Trade under 28 U.S.C. § 1581(i). The limit is two years, and when that clock starts is not settled. Plan around the earliest possible date, about February 4, 2027 (DWT, Oct 14, 2026). Plaintiffs with a reliquidation order file in CAPE Phase 3 through their attorney (Troutman, Oct 2, 2026).
• The class. On October 8, 2026 the court certified a class in Freestyle World v. CBP: every importer of record who paid IEEPA duties from February 1, 2025 to February 19, 2026 and did not file its own suit (Slip Op. 26-123). Members file nothing. DWT reports that duties under the Brazil and India IEEPA orders are not included (DWT, Oct 14, 2026). The class has no refund order yet. Do not rely on it to protect your deadline.

Either way, the refund is paid like any other: by ACH to a US account or a notify party. Set up the payment path now so it is ready. See All IEEPA Refund Deadlines and Sue or Wait for the IEEPA Refund Class?. Talk to a customs attorney about your situation.

Should we file CAPE before the bank question is solved?

Yes. File your CAPE Declaration as soon as your entries and ACE access are ready. The 80-day window keeps moving every day. An accepted Declaration with a payment on hold is better than entries that aged past day 80 while you waited.

Then set up the payment path before the refund is issued.

Quick reference: payment options for a foreign IOR

Frequently Asked Questions

We are a Canadian company and were the importer of record. Can we file CAPE? Yes. Filing depends on being the importer of record on the entry, not on where your company is based. The barrier is payment. File, then set up a US account or a broker notify party before the refund is issued.

Can my US customs broker receive the refund for us? Yes, through Form 4811, which CBP's rule names as the route for foreign importers (FR 2025-24171). The broker must be on file in your ACE profile, its number must be in box 28 of the entry summary (CSMS #67648307), and it needs its own ACH enrollment (FR 2025-24171). Agree in writing how it passes the money to you.

Can a new broker be our notify party for entries another broker filed? We found no CBP answer for this case. The new broker's number would have to be in box 28 of each entry summary, and ACE refuses a PSC on an entry once it is in a CAPE Declaration (CSMS #68397097). Ask your broker and CBP before relying on it.

Can CBP send the refund to a bank account outside the US? No. ACH refunds go to a US bank account enrolled in ACE, either yours or your notify party's. The only other option in the rule is a paper check under a hardship waiver (FR 2025-24171).

Can we use someone else's US bank account? CBP's rule names only your own US account or your broker. One importer reported on Reddit borrowing a law firm's account for a 4% fee (r/CustomsBroker, 1uem08r). That is a single post, not a CBP route. Ask a customs attorney before you route a refund through anyone else's account.

Can we get a paper check? Only with a hardship waiver under 31 CFR 208.4. Ask in writing to frn-achrefundsupport@cbp.dhs.gov and state the waiver ground that applies (FR 2025-24171). The rule does not list the grounds, so do not count on it.

Our entries liquidated more than 80 days ago. Does being foreign change anything? No. The same paths apply: your own suit at the Court of International Trade, or the certified class, which has no refund order yet. The two-year limit to sue has a start date that is not settled, so plan around about February 4, 2027. Talk to a customs attorney about your situation.