IEEPA Refund Sitting at Treasury? Why 1,880 Importers Aren't Getting Paid (May 2026 ACH Action Guide)

IEEPA Refund Sitting at Treasury? Why 1,880 Importers Aren't Getting Paid (May 2026 ACH Action Guide)

Three weeks after Customs and Border Protection's Consolidated Automated Payment Engine (CAPE) opened on April 20, 2026, the IEEPA refund pipeline is doing exactly what CBP said it would do — and exactly what a lot of importers did not prepare for. Through the second week of May, CBP has cleared roughly $35.5 billion in IEEPA refund authorizations across more than 87,000 validated CAPE Declarations. Refund payments started landing in importer bank accounts on or about May 12. The pipeline is moving.

But a very specific subset of those refunds is sitting at the Treasury Department instead of in importer accounts. Industry estimates put the stuck-refund count at approximately 1,880 consolidated refund batches — refunds that CBP validated, transmitted to Treasury for disbursement, and that Treasury cannot pay because the receiving importer has either no ACH bank account on file with ACE or stale ACH information that fails Treasury's account validation check. CBP stopped issuing paper refund checks on February 6, 2026. There is no fallback. If your ACH information is wrong, your refund waits.

This guide walks through the operational fix: why CBP went ACH-only, the difference between a duty-payment ACH account and a refund-receiving ACH account (they are not the same), the step-by-step process for adding or updating your refund ACH in the ACE Portal, the SF 3881 enrollment form, the non-resident importer (NRI) trap, the REV-603 status codes that tell you exactly where your refund is in the pipeline, and the action checklist for importers whose refund has not landed yet. If you have a CAPE Declaration that shows Accepted but no money in your account, this is the article to read this week.

The 1,880-Importer Problem

CBP runs two related reports out of ACE that together tell you whether your refund is moving. REV-603 is the master refund-status report — it shows every IEEPA refund line CBP has authorized, the current status, and the Treasury disbursement path. REV-613 is the rejected-refunds subset — it shows specifically refunds that CBP attempted to send via ACH but Treasury could not deliver because of an account problem.

The 1,880 figure traces back to REV-613. Each line on REV-613 represents one consolidated refund batch — typically a CAPE Declaration's worth of entries rolled up into a single ACH payment instruction — that Treasury bounced back to CBP with a "Funds Diverted" or "Check/ACH Returned" status. The underlying reasons fall into four buckets:

The largest bucket is importers who never enrolled in refund-specific ACH at all. Many importers assumed that their existing ACH enrollment for duty payments (the account they use to wire duty to CBP at the time of entry) would also receive refunds. It does not. CBP's refund-enrollment path is administratively separate from the duty-payment path, runs on a different ACE form, and requires the importer to designate the bank account that should receive any refund issued under that importer's IOR number.

The second bucket is importers who enrolled but have stale or closed bank accounts on file. Banks merge, account numbers change, and CFOs change wires without updating the ACE refund record. Treasury's pre-disbursement validation check catches mismatched routing numbers and closed account numbers, returns the payment to CBP, and the refund flips to REV-613 status.

The third bucket is non-resident importers (NRIs) operating as the importer of record without a U.S. bank account at all. ACH is a U.S. domestic banking rail. Treasury cannot disburse an ACH payment to a foreign bank account. NRIs have valid refund claims but no compliant payment destination, and CBP's published guidance does not yet provide a workaround other than "open a U.S. bank account" or "designate a U.S. broker recipient via Form 4811."

The fourth bucket is importers whose Form 4811 designates a recipient (typically a broker) whose own ACH information is incorrect. When Form 4811 is on file, Treasury pays the designated recipient rather than the IOR. If the recipient's ACH record is stale, the refund bounces back the same way — and the IOR may not know for weeks that the broker recipient is the actual cause of the delay.

For importers in any of these four buckets, the refund will not arrive on its own. CBP does not have a "retry until it works" automation; it has a manual enrollment-correction process that runs through ACE Portal and Treasury's enrollment system, and the clock on that process starts only when the importer (not CBP) submits corrected information.

Why CBP Went ACH-Only on February 6

CBP's February 6, 2026 cutover to ACH-only refunds was not an IEEPA-specific decision. It was a Treasury-wide modernization push that has been in motion since 2022, when the Treasury Department began deprecating paper Treasury checks across all federal disbursement programs. The IEEPA refund timing simply collided with the cutover — CAPE went live two and a half months after paper checks ended, so every IEEPA refund batch has been ACH-only from day one of the program.

The operational consequence is that there is no longer a check-printing fallback at the National Finance Center for refunds that bounce ACH. When a refund cannot be delivered electronically, the only remediation path is for the importer to fix the ACH record and CBP to retry. There is no "we will mail you a check while you sort out your bank info" pathway anymore. The longer the ACH record stays broken, the longer the refund waits in CBP's pending-disbursement queue.

The cutover also eliminated CBP's previous tolerance for ACH/check hybrid refund handling. Before February 6, a CFO who knew their ACH was bad could ask CBP to issue a check, accept the longer timeline, and avoid the ACH correction work. That option is closed. Every importer expecting an IEEPA refund must have functional ACH on file or accept that the refund will not arrive at all.

For importers who genuinely cannot enroll in ACH — primarily NRIs without a U.S. banking relationship — the practical workaround during May 2026 is to designate a U.S. licensed customs broker as the refund recipient via Form 4811 (Special Address Notification). Form 4811 transfers the refund-receiving authority to the named recipient, who then must have their own valid ACH on file. This is administratively cleaner than trying to fix the underlying NRI banking gap, but it requires the broker to actually accept the funds and remit to the importer through a separate commercial arrangement — usually with a brokerage handling fee netted out of the refund.

Duty-Payment ACH and Refund ACH Are Different Accounts

This is the single most common point of confusion, and it is responsible for a meaningful share of the 1,880 stuck refunds. CBP runs two separate ACH enrollment paths in ACE Portal, each tied to a different transaction type:

ACH Debit (also called PMS or Periodic Monthly Statement ACH) is the path importers use to *pay* duty to CBP. It authorizes CBP to pull funds from the designated account when duty is owed at the time of entry summary or under a periodic monthly statement. This is the account that flows out, not the account that flows in.

ACH Credit / Refund ACH is the path importers use to *receive* refunds from CBP. It authorizes Treasury to push funds into the designated account when a refund is owed. This is a separate enrollment, lives on a separate ACE Portal screen, and is keyed off the IOR number for refund delivery.

An importer can have a valid duty-payment ACH enrollment and a missing refund ACH enrollment at the same time. CBP's ACE Portal will not warn the importer about the missing refund enrollment until a refund is actually authorized and Treasury attempts the disbursement. By then, the refund is already in REV-613 status and the importer is starting the enrollment process from scratch — typically a 7-to-10-business-day cycle from form submission to active ACH receiving status.

The duty-payment account and the refund account can be the same bank account if the importer chooses, but the importer must explicitly enroll that account on the refund path. The ACE system does not auto-populate the refund ACH from the duty-payment ACH; that is a deliberate design choice that prevents an unauthorized cross-credit but creates the enrollment-gap risk.

How to Enroll or Update Your Refund ACH in ACE Portal

The enrollment process runs through ACE Portal under the importer's IOR account. Most importers complete it in 20 to 30 minutes, though the actual ACH activation at Treasury takes an additional 5 to 7 business days after submission.

Step 1: Log in to ACE Secure Data Portal at ace.cbp.dhs.gov using an Account Owner or Proxy Account Owner credential. Standard Trade Account Users do not have permissions to update banking information; you need an account-level role.

Step 2: Navigate to the Accounts tab, select the importer account associated with the IOR number you are updating, and open the Bank Account Information sub-screen. This is distinct from the duty-payment bank info screen — look specifically for the section labeled "Refund Deposit Account" or "Disbursement Account."

Step 3: Add or update the bank account. You will need the bank's nine-digit routing number, the importer's account number, the account type (checking or savings), and the bank name. CBP validates the routing number in real time against the Federal Reserve database; an invalid routing number cannot be saved.

Step 4: Complete and upload Standard Form 3881 (ACH Vendor / Miscellaneous Payment Enrollment). SF 3881 is the underlying Treasury enrollment document, and CBP requires a completed, bank-signed SF 3881 to activate any new refund ACH account. The form has three sections: agency information (CBP, prefilled), payee/company information (the importer fills this in), and financial institution information (the importer's bank fills in and signs). Most banks can complete and return SF 3881 within 1 to 3 business days.

Step 5: Submit the SF 3881 through ACE Portal's document-upload interface. Once submitted, the enrollment moves into Treasury's queue for activation. Activation typically takes 5 to 7 business days, after which the refund ACH path is live and CBP will attempt to redeliver any pending refunds on the next disbursement cycle (usually within 14 days of activation).

Step 6: Verify activation by pulling REV-603 after activation. A successful re-disbursement will show the refund status flipping from "Funds Diverted" or "Check/ACH Returned" to "Treasury Issued" and then to "Paid." If the refund stays in the diverted status after 21 days post-activation, escalate to CBP's Revenue Division through the National Finance Center contact path published in CSMS 68340863.

The Non-Resident Importer Trap

NRIs — Canadian, Mexican, European, and Asian importers who hold a U.S. IOR number but no U.S. operating presence — face a harder version of this problem. ACH is a U.S. domestic payments rail; Treasury cannot send an ACH credit to a foreign bank account. The IEEPA refund eligibility is unaffected by NRI status (foreign IORs are eligible for refunds on duties they actually paid), but the disbursement mechanics break at the banking layer.

Three workarounds have emerged in the first month of CAPE refunds, each with its own friction:

Open a U.S. bank account. A Canadian or Mexican company can open a U.S. business checking account at a U.S. branch of a Canadian bank (RBC U.S., TD Bank, BMO Harris) or a U.S. money-center bank with a cross-border desk (Chase, BofA, Citi). Account-opening for foreign-domiciled entities typically takes 4 to 8 weeks and requires KYC documentation including beneficial ownership certifications and a U.S. registered agent. For NRIs with material IEEPA refund exposure (typically more than $100,000 in pending refunds), the carrying cost of opening a U.S. account is usually less than the lost time-value of refund delay.

Designate a U.S. broker recipient via Form 4811. Form 4811 (Special Address Notification) lets the IOR designate a third-party recipient — typically a licensed U.S. customs broker — to receive refunds on its behalf. The broker receives the refund into its own U.S. ACH account, then remits to the foreign importer through a commercial wire (typically with a 1% to 3% handling fee netted out). The Form 4811 path is the fastest workaround for NRIs who already have a U.S. broker relationship.

Wait for CBP to publish a non-ACH alternative. Industry trade associations including the National Customs Brokers and Forwarders Association of America (NCBFAA) have asked CBP and Treasury to publish a check or international-wire alternative for NRIs. As of mid-May 2026, no such alternative has been published. NRIs without one of the two workarounds above will see their refunds sit in REV-613 indefinitely.

The cost-benefit analysis for NRIs favors the Form 4811 path for refunds under $250,000 and the U.S. bank account path for refunds above that threshold, with the breakeven driven primarily by the per-refund fee structure the broker offers and the projected volume of future IEEPA refunds the NRI expects to claim.

REV-603 Status Codes: Where Is My Money Right Now?

Pulling REV-603 from the ACE Reports interface is the single most useful diagnostic for stuck IEEPA refunds. The report lists every authorized refund line tied to your IOR, with a current "Refund Secondary Status" code that tells you exactly where the payment is in the pipeline. The codes you will encounter most often:

Pending Disbursement. CBP has authorized the refund and queued it for Treasury. No action needed; the next Treasury disbursement cycle (typically weekly) will pick it up. Expect movement within 7 days.

Sent to Treasury. CBP has transmitted the payment instruction to Treasury, and Treasury is in the validation phase. No action needed; Treasury validation typically completes within 3 to 5 business days.

Treasury Issued. Treasury has released the ACH payment to the receiving bank. The refund should hit the importer's account within 1 to 2 business days. If you do not see the deposit within 5 business days of Treasury Issued, contact your bank — the ACH has been transmitted on Treasury's side.

Paid. The receiving bank has confirmed receipt. The refund cycle is complete for this line.

Funds Diverted. Treasury attempted disbursement but the bank rejected the ACH (usually wrong routing number, closed account, or account-name mismatch). The refund has been returned to CBP and is awaiting corrective action from the importer. This is the REV-613 status. Action required: update or re-enroll ACH per the Step 1–Step 6 process above.

Check/ACH Returned. Similar to Funds Diverted but specific to cases where the bank attempted to credit the account and the credit bounced back. Less common than Funds Diverted but treated the same way operationally.

Hold. CBP has paused disbursement pending an internal review unrelated to the ACH path — usually a CAPE Declaration validation question or a request for additional supporting documentation. Action required: respond to the CBP request, typically issued via CSMS or directly to the broker who filed the underlying CAPE Declaration.

The status codes update in batch, typically once per business day. An importer running a weekly REV-603 pull and triaging by status code can catch most stuck refunds within 7 to 14 days of the underlying issue arising, which is fast enough to fix and reissue within the standard 60-to-90-day CAPE refund window.

This Week's Action Checklist

Whether your refund has already landed, is in flight, or is showing on REV-613, five actions this week will materially de-risk the rest of your IEEPA refund pipeline:

Pull REV-603 today for every IOR number you operate under. Sort by Refund Secondary Status and flag every line with Funds Diverted, Check/ACH Returned, or Hold status. These are the lines that need immediate attention.

Confirm your refund ACH enrollment is current in ACE Portal under each IOR account. Verify that the routing number, account number, and bank name match the account you actually use today. If anything is stale, start the SF 3881 process now — it takes 5 to 7 business days to activate.

Audit any active Form 4811 designations. If you have a broker recipient designated for refunds, confirm with the broker that their refund ACH is current and that they are tracking your specific refund batches. A broker recipient with a stale ACH bounces your refund just as effectively as your own stale ACH.

Build a weekly REV-603 monitoring cadence. The IEEPA refund pipeline is going to run for at least 6 to 9 more months as CAPE processes the backlog of pre-cutover entries, and refund-status codes change frequently as Treasury cycles through disbursement batches. Pulling REV-603 weekly catches issues before they age out of efficient remediation.

If you operate as a non-resident importer, decide on a workaround this week. Either commit to opening a U.S. bank account (start the application this week to give the 4-to-8-week timeline a chance to resolve before peak refund issuance in June and July), or file Form 4811 designating a U.S. licensed broker as your refund recipient. Sitting and waiting for CBP to publish a non-ACH alternative is a losing strategy on the current timeline.

The Bigger Picture

The 1,880 stuck refund batches are not a CAPE problem and not a CBP problem. They are a banking-infrastructure problem that fell on importers without warning when the February 6 paper-check cutover removed the legacy fallback. CBP's CAPE pipeline is doing exactly what CBP designed it to do: authorize valid refunds, transmit to Treasury, and issue ACH on a weekly cycle. The bottleneck is on the receiving end, in importer back offices that did not maintain a refund ACH enrollment because there had never been a reason to.

The fix is administrative, not legal. There is no policy challenge to file, no protest to lodge, and no appeal to await. The 7-to-10-day SF 3881 enrollment cycle is the entire critical path between a stuck refund and a paid refund for the duty-payment-only-ACH and stale-account categories. For NRIs, the workaround takes longer — typically 4 to 8 weeks for a U.S. bank account or 1 to 2 weeks to set up Form 4811 with a broker recipient — but the path is well-trodden by the U.S. customs broker community and most major brokers have a turnkey refund-handling product line.

For importers with IEEPA refund exposure in the six-to-eight-figure range, the time-value of fixing ACH this week instead of waiting for the next quarterly back-office review is straightforward to calculate. A $1 million refund delayed 60 days at a 5% cost of capital is approximately $8,200 in carrying cost — more than enough to justify the half-day of administrative work that the SF 3881 cycle requires.

For context on the underlying CAPE program mechanics, see our IEEPA Refund Guide. For the top 10 reasons CAPE Declarations themselves get rejected before the refund-disbursement stage, see the CAPE Declaration Rejected: Top 10 Validation Failures. For the first-refunds tracking timeline through May 11, see the First IEEPA Refunds May 11 importer checklist.

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