As the CBP CAPE portal begins processing IEEPA tariff refunds, a new issue is emerging across the market. It is not eligibility, classification or claim quality. It is payment execution.
For nonresident importers (NRIs), IEEPA refunds are becoming increasingly difficult to access, not because claims are being denied, but because funds cannot be disbursed. Early CAPE activity is making this clear. The challenge is no longer filing. It is getting paid.
The issue: Approved IEEPA refunds without a payment path
CBP is issuing refunds through ACH (Automated Clearing House) payments tied directly to ACE accounts with valid U.S. banking information. While this system works efficiently for U.S.-based importers, it creates a structural gap for nonresident importers operating as importer of record.
If there is no U.S. bank account, there is no practical way to receive an ACH refund. Without ACH capability, the IEEPA refund process effectively stops at the point of payment.
This is not theoretical. It is already showing up in practice. Nonresident importers who have properly filed entries, paid IEEPA duties and submitted valid refund claims are finding themselves unable to complete the process. Claims can be submitted through CAPE, and CBP can review and approve them. However, without a valid ACH setup tied to ACE, the funds have nowhere to go.
The result is delay, uncertainty and unresolved refunds.
Where nonresident importers are exposed
The impact is concentrated but significant. Any nonresident importer without a U.S. banking relationship is exposed, including companies acting as importer of record without U.S. entities, organizations relying on brokers or third parties for filing, and businesses that historically did not require U.S. financial infrastructure.
Under the IEEPA refund framework, that gap now directly impacts cash recovery.
Why CAPE timelines do not solve the problem
CBP has indicated expected timelines of approximately 45 days for review after CAPE acceptance, followed by 60 to 90 days for refund processing. Importers are moving quickly to meet these timelines and submit claims.
Timing, however, is not the constraint. If the payment mechanism is not in place before or during that process, the timeline becomes secondary. Claims may move through review and approval, but funds cannot be disbursed.
The shift: From submission to full execution
The IEEPA refund process is no longer limited to identifying overpayments or preparing accurate submissions. It now requires alignment across the full lifecycle, including ACE data, CAPE submission, CBP review and final payment execution. As outlined in our overview of the CAPE portal for IEEPA refunds, the process is structured but not passive, and execution gaps can create downstream issues.
The ACH refund requirement is a gating issue. Without a U.S. bank account, ACH payments cannot be processed, and without ACH capability, refunds cannot be distributed.
ACE reporting and visibility: What NRIs need to monitor
With CAPE now live, importers can track refund activity through ACE reporting. Key reports include the REV-603 Trade Refund Report for tracking refund status and history, the REV-613 ACH Rejected Refunds Report for identifying failed payments and the REV-615 report for visibility into refunds issued, pending or applied.
For nonresident importers, this visibility is critical to confirm whether refunds have been processed, identify ACH-related payment failures and ensure funds are not missed or left unresolved. Access alone is not sufficient. Data must be interpreted and reconciled to entries and filings.
Compliance still applies to IEEPA refunds
The CAPE portal reflects CBP’s shift toward a more centralized, transparent and auditable refund process. Refund submissions are formal filings with U.S. Customs and may be reviewed, questioned or audited.
Key considerations include confirming eligibility for the refund, reviewing entry data and classifications, ensuring documentation aligns with the claim and verifying that filings reflect what was declared to CBP. Payment challenges do not replace compliance risk, and both must be managed in parallel.
What nonresident importers should do now
This issue can be addressed, but it requires early action. For organizations evaluating IEEPA refund recovery strategies, including eligibility and filing approach, it is important to align payment readiness with the broader refund process. Nonresident importers should confirm whether an ACH refund account is properly established in ACE, evaluate U.S. banking options aligned with CBP requirements and coordinate between importer, broker and finance stakeholders.
In addition, importers should actively review ACE reporting to monitor refund status and identify potential payment issues. Ensuring that payment infrastructure is in place before or during filing is critical, as waiting until claims are approved introduces avoidable delays.
What this means for IEEPA refund recovery
The IEEPA refund process is not complete when a claim is filed. It is complete when the funds are received. For nonresident importers, that requires having the appropriate payment infrastructure in place.
Without it, even accurate and approved claims can remain unresolved.
Next steps for nonresident importers
If you are a nonresident importer pursuing IEEPA refunds without a U.S. bank account or ACH setup, this is not an issue that will resolve within the CBP system. A structured, compliant approach can establish a U.S.-based payment mechanism that aligns with CBP requirements and allows refunds to be received, tracked and reconciled properly.
We are actively working with importers facing this issue and can help ensure refunds are received and not left unresolved.
