The U.S. Department of the Treasury will cease issuing paper checks for all U.S. Customs and Border Protection (“CBP”) refunds starting on February 6, 2026 according to an Interim Final Rule. A recipient may continue to receive paper checks provided that they have an approved waiver in place in accordance with 31 C.F.R. § 208. Individuals and firms seeking refunds for IEEPA tariffs are unlikely to fall under one of the specific cases provided for in 31 C.F.R. § 208.4(a). Therefore, importers seeking possible refunds of IEEPA tariffs in the event that the Supreme Court finds such tariffs unlawful should ensure that Automated Clearing House (“ACH”) refunds are authorized in the Automated Commercial Environment (“ACE”) Portal.

ACH Refund is available to anyone who has a federally assigned taxpayer identification number, Social Security number, or CBP’s assigned number, and a U.S. bank account with U.S. bank routing number. Trade users can use the new ACH refund authorization tool in ACE to complete this process using the one-page guide provided by CBP.

The basic steps to ensure proper ACH refund receipt are as follows.

  1. Log in to your ACE Portal top account as TAO or as an authorized Proxy TAO or Trade Account User.
  2. Navigate to the importer sub-account view and locate the ACH Refund Authorization tab.
  3. View, add, and update U.S. bank information for receiving refunds

For more information on authorizing ACH refunds and other questions regarding ACE Portal functionality, please feel free to reach out to Crowell & Moring for assistance.

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Andrew Schlegel is an international trade analyst III in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border

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Andrew Schlegel is an international trade analyst III in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border Protection (CBP). He works closely with attorneys developing courses of action for clients impacted by investigations under Section 301 of the Trade Act of 1974 and Section 232 of the Trade Expansion Act of 1962. Andrew also supports unfair trade investigations, including antidumping (AD) and countervailing duty (CVD) investigations, sunset reviews, and changed circumstance reviews before the Department of Commerce and the International Trade Commission (ITC).

Prior to joining Crowell & Moring, Andrew worked as an intern at SAP’s Government Affairs Business Development Team in Berlin, Germany. There, he analyzed the effects of regulatory changes on SAP business operations and expansion opportunities. Before this, he completed an internship at the International Trade Administration’s Office of Energy and Environmental Industries. While there, he developed the U.S. Energy Trade Dashboard, an interactive data visualization tool for use by professionals and researchers to analyze how energy supply chains have developed.

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