Daniel Covarrubias

Policy Proposal

The Binational Customs Agency

A Vision for US-Mexico Joint Customs Operations

$800B+

Annual US-Mexico bilateral trade (2023)

7.3M

Cargo trucks crossing the border annually

76M

Total vehicles crossing annually

$1T

Projected bilateral trade within the next decade

Dr. Daniel Covarrubias

Texas Center for Border Economic and Enterprise Development | TAMIU

Gerónimo Gutiérrez Fernández

Former Mexican Ambassador to the United States (2017–2018) | Former Managing Director, NADBank

February 2025

The Challenge

Two Systems, One Border

The US-Mexico border operates under two fundamentally different customs philosophies. U.S. Customs and Border Protection (CBP) prioritizes security and law enforcement — preventing terrorism, narcotics trafficking, and illegal immigration. Mexico's National Customs Agency (ANAM) operates primarily as a revenue-generating body, collecting nearly $59 billion in 2023, with a focus on tax enforcement and compliance. These parallel but separate systems increasingly fail to provide the seamless border operations that deeply integrated economies demand.

The institutional divide goes deeper than mission. CBP is a civilian agency with 68,069 authorized positions (FY 2025). Mexico recently militarized its customs operations through ANAM — deploying military personnel who often lack specialized customs expertise, creating operational challenges in processing trade flows. This organizational mismatch makes bilateral coordination difficult at every level.

Meanwhile, infrastructure hasn't kept pace: no new commercial bridge has been built in 24 years, despite trade volumes hitting historic highs. When Mexico's computer systems fail (which happens periodically), operations at the World Trade Bridge in Laredo halt — stopping 18,000+ trucks per day and costing millions in lost revenue.

 U.S. (CBP)Mexico (ANAM)
Primary MissionSecurity & Law EnforcementRevenue Collection
StructureCivilian agencyMilitarized (recent)
LPI Customs Rank11th globally54th globally
FY2025 Positions68,069 authorizedStaffing challenges

Shared Security

The Convergence of Threats

Northbound: The fentanyl crisis — over 70,000 synthetic opioid overdose deaths in 2022 in the United States. DHS has defined fentanyl trafficking as its number one operational challenge. Unlike plant-based drugs, synthetic opioids rely on widely traded chemical precursors with legitimate commercial uses, making customs detection extraordinarily difficult.

Southbound: Weapons trafficking — the vast majority of weapons in the hands of Mexican crime organizations come from the United States. Estimates range up to 500,000 weapons entering Mexico annually from the U.S. A very small proportion is actually stopped at the border.

Security concerns have become justification for trade disruptions (IEEPA tariffs, 25% tariffs on Mexican goods). The BCA proposes separating security enforcement from commercial facilitation — solving both problems simultaneously rather than using one as a weapon against the other.

Northbound Threats

  • Fentanyl & synthetic opioids
  • Chemical precursors
  • Narcotics trafficking

The BCA addresses both directions simultaneously

Southbound Threats

  • Weapons & firearms
  • Ammunition
  • Bulk cash smuggling

The Solution

A New Institutional Framework

The BCA builds on two proven models of US-Mexico bilateral cooperation.

Model 1

International Boundary and Water Commission (IBWC)

  • Treaty-based framework operating since 1944
  • Distinct U.S. and Mexican Sections maintaining jurisdiction within their territories
  • Formal "minutes" system for documenting agreements
  • Has survived decades of political cycles while managing shared resources

Model 2

North American Development Bank (NADBank)

  • Joint U.S.-Mexico institution with equal ownership and governance
  • Shared funding, staffing, and operational independence
  • Professional standards maintained across political transitions

The BCA takes the IBWC model for its initial structure (separate sections, sovereignty protections) with the NADBank model as its evolution pathway (deeper integration as trust builds).

Governance Structure

Board of Directors with equal representation from both nations

Two co-directors (one from each country)

Advisory council including private sector stakeholders

Independent oversight committee for transparency and accountability

Organizational Structure

Five Specialized Divisions

The Path Forward

From Concept to Reality

Phase 1

Build Momentum Through Existing Mechanisms

  • U.S.-Mexico High-Level Economic Dialogue (HLED) — cabinet-level conversations
  • 21st Century Border Initiative — operational blueprints
  • USMCA Trade Facilitation and Competitiveness Committees — stakeholder engagement

Phase 2

2026 USMCA Review

  • Formalize discussions during the joint review
  • Incorporate BCA into the modernization of North American trade architecture
  • Side letter or additional commitment (avoids need for full legislative approval)

Phase 3

Initial Operations

  • Distinct national sections with clear sovereignty protections (IBWC model)
  • Pilot at 2–3 major ports of entry
  • Build operational trust between partners

Phase 4

Deeper Integration

  • Evolve toward NADBank-style shared operations
  • Potential expansion to include Canada → North American Customs Agency

Proof of Concept

This Already Works — at Small Scale

1

Unified Cargo Processing (UCP)

Joint CBP-SAT cargo inspections already operating at select ports of entry.

2

Laredo International Airport

Mexican Customs officers review air cargo on-site for auto, electronics, and aerospace industries.

3

Mesa de Otay

CBP pre-inspection of US-bound agricultural shipments (USDA National Agriculture Release Program).

4

San Jerónimo / Santa Teresa

Only UCP facility south of the US-Mexico border. CBP and SAT officers work side-by-side. FAST lanes eliminate duplicate inspections. Supports Foxconn's 10,000-employee campus in Ciudad Juárez.

5

Cross Border Express (CBX)

San Diego-Tijuana airport connection. First discussed in 1989, operational since 2015. Full coordination of Mexican and U.S. authorities. Proof that "this-will-never-happen" proposals can become reality.

Part of a Larger Framework

The BCA Within USMCA 2.0

The Binational Customs Agency is one of three institutional pillars proposed for modernizing North American trade governance.

SECURITY

Binational Customs Agency (BCA)

Enhanced Security

You are here

TECHNOLOGY

NADICI

Technology & Digital Infrastructure

Read proposal

INDUSTRIAL POLICY

NAICC

Industrial Policy & Coordination

Read proposal

About the Authors

Dr. Daniel Covarrubias

Texas A&M International University

  • Director, Texas Center for Border Economic and Enterprise Development
  • A.R. Sanchez, Jr. School of Business, Texas A&M International University
  • Leads the Logistechs Living Lab
  • Research: cross-border trade, logistics technology, US-Mexico economic integration
  • Media: Wall Street Journal, Texas Standard, PBS

Gerónimo Gutiérrez Fernández

Former Mexican Ambassador to the U.S.

  • Former Mexican Ambassador to the United States (2017–2018)
  • Former Managing Director, North American Development Bank (NADBank)
  • Senior positions in Mexico's Ministries of Economy, Foreign Affairs, and Finance
  • Currently Senior Advisor at Covington & Burling, LLP
  • Managing BEEL Infrastructure; serves on multiple advisory boards focused on bilateral relations

Read the Full Proposal

Download the complete paper or connect with the Texas Center for Border Economic and Enterprise Development for speaking and media inquiries.