THE VIGILANT VIGIL – 13TH EDITION
Welcome, visitor, to the Vigil. Here you will find a summation of current global trade changes and regulatory updates. We aim to deliver helpful insights in a timely and relevant manner, to help you remain vigilant in an ever-evolving trade environment.
The Editing Director (T.E.D.)’s Foreword:
Welcome to the thirteenth edition of the Vigilant Vigil.
Let’s be honest.
The trade community has been enjoying a bit of drama lately.
We’ve had the ongoing IEEPA refund saga. We’ve had CAPE submissions, rejected claims, refund checks arriving unexpectedly fast, Section 122 challenges, and enough litigation updates to make some of us feel like we’re watching a legal version of a reality television series.
And then there is Judge Eaton.
Now, judges are generally known for being patient. Deliberate. Measured.
Judge Eaton appears to have looked at the pace of some of these developments and politely decided he had exhausted his supply of patience.
Watching the Court of International Trade effectively summon the CBP Commissioner to explain delays felt a little bit like watching a principal call a student into the office and ask, “Would you care to explain yourself?”
I won’t pretend I wasn’t reaching for the popcorn.
But while many of us have been captivated by the main stage production—IEEPA, CAPE, Section 122, refunds, protests, and court battles—we may have missed what was happening behind the curtain.
Because sanctions never stopped.
OFAC never stopped.
Export controls never stopped.
The European Union never stopped.
The United Kingdom never stopped.
And judging from this week’s updates, they have all been quite busy while we were focused elsewhere.
This edition contains sanctions actions, new sanctions authorities, new general licenses, new exceptions, new restrictions, and continued tightening of controls around the globe. At the same time, governments continue refining trade agreements, customs valuation practices, export licensing frameworks, and enforcement priorities.
It’s a good reminder that compliance professionals can develop tunnel vision.
And frankly, who could blame us?
When an issue like IEEPA refunds consumes every conference call, every webinar, every LinkedIn post, every executive meeting, and every budget discussion, it’s natural to focus on the loudest issue in the room.
But risk rarely announces itself that clearly.
Sometimes the biggest compliance problem is the one you’re not talking about.
While everyone is debating refunds, someone else is adding names to a sanctions list.
While everyone is analyzing a court decision, someone else is issuing a new export control.
While everyone is fighting today’s battle, tomorrow’s risk is quietly developing in the background.
That doesn’t mean we should stop paying attention to the tariff drama. Far from it.
It simply means we need to remember that trade compliance is a very big universe, and the universe does not pause because we are focused elsewhere.
So this week’s message is simple:
Enjoy the tea.
Follow the court cases.
Watch the refund process unfold.
But don’t forget to keep one eye on the rest of the compliance landscape.
Because while we’ve all been watching the headline act, there has been an awful lot happening backstage.
And sometimes that’s where the next story begins.
Let’s stay vigilant.
Jamie Adams, LCB, CCS
Director of Global Compliance Solutions at Vigilant GTS
In this volume, we will explore:
- CSMS updates
- Updates to the Federal Registry, for both policy and lots of sanctions actions
- Cooperative call outs to other blogs
- Where to find us
- Be sure to check out our weekly edition of Trade Buzz
Let’s veer into it, shall we?
**The following contains links and citations from multiple US government agencies and other credible sources. Vigilant GTS LLC is not the source material but simply compilating the information.**
CSMS Updates
**The following are short summaries of the actual information provided by CSMS. To stay up to date with announcements and news, please subscribe at: https://www.cbp.gov/webform/subscribe-receive-cbp-access-updates **
CSMS # 68769970 – UPDATE: New CERT Date for AD/CVD Case Information Query is June 4, 2026
Please be advised that the updates for the AD/CVD Case Information Query returning an unlimited number of records for Manufacturer Details and Foreign Exporter Details will now deploy to the CERTIFICATION (CERT) environment on June 4, 2026.
The ACE CATAIR AD/CVD Case Information Query V11 is currently posted under the Draft Chapters: Future Capabilities section on CBP.gov. This update is scheduled to deploy to the PRODUCTION (PROD) environment on July 9, 2026.
CSMS # 68769970 – UPDATE: New CERT Date for AD/CVD Case Information Query is June 4, 2026
Federal Register Updates
**These are just a sampling of the many updates and changes made by the Federal Register. For a more comprehensive list, or to subscribe to the updates yourself, follow the link below, and never miss a thing.**
https://www.federalregister.gov
Implementing Certain Tariff-Related Elements of a Trade and Security Agreement Between the American Institute in Taiwan and the Taipei Economic and Cultural Representative Office in the United States
| FR Document: 2026-10571 Citation: 91 FR 31818 |
PDF Pages 31818-31822 (5 pages) Permalink |
| Abstract: On September 5, 2025, President Trump issued Executive Order 14346 (Modifying the Scope of Reciprocal Tariffs and Establishing Procedures for Implementing Trade and Security Agreements). Executive Order 14346 directed and authorized the Secretary of Commerce (Secretary) and the United States Trade Representative (Trade Representative) to implement the terms of any framework trade and security agreement or final trade and security agreement concluded between the United States and a foreign… | |
Distribution of Continued Dumping and Subsidy Offset to Affected Domestic Producers
| FR Document: 2026-10350 Citation: 91 FR 30804 |
PDF Pages 30804-31019 (216 pages) Permalink |
| Abstract: Pursuant to the Continued Dumping and Subsidy Offset Act of 2000, this document is U.S. Customs and Border Protection’s (CBP) notice of intent to distribute assessed antidumping and countervailing duties (known as the continued dumping and subsidy offset) for Fiscal Year 2026 in connection with countervailing duty orders, antidumping duty orders, and findings under the Antidumping Act of 1921. This document provides instructions for affected domestic producers, or anyone alleging eligibility… | |
Sanctions Action
| FR Document: 2026-10259 Citation: 91 FR 30388 |
PDF Pages 30388-30395 (8 pages) Permalink |
| Abstract: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is publishing the names of one or more persons and vessels that have been placed on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List) based on OFAC’s determination that one or more applicable legal criteria were satisfied. All property and interests in property subject to U.S. jurisdiction of these persons are blocked, and U.S. persons are generally prohibited from engaging in transactions… | |
Sanctions Action
| FR Document: 2026-10518 Citation: 91 FR 31522 |
PDF Pages 31522-31524 (3 pages) Permalink |
| Abstract: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is publishing the names of one or more persons that have been placed on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List) based on OFAC’s determination that one or more applicable legal criteria were satisfied. All property and interests in property subject to U.S. jurisdiction of these persons are blocked, and U.S. persons are generally prohibited from engaging in transactions with them. | |
News from other esteemed sources:
BAKER/MCKENZIE
EU: Council and Parliament reached an agreement on the implementation of the EU-U.S. Trade Deal
On 20 May 2026, the Council presidency and the European Parliament reached an agreement on two regulations aimed at implementing the tariff-related aspects of the framework on a agreement on Reciprocal, Fair, and Balanced Trade between the EU and the…
Read more…
President Trump Signs New Executive Order Imposing US Secondary Sanctions Targeting Cuba
05/21/2026
On May 1, 2026, President Trump signed Executive Order 14404 (“EO 14404”) entitled “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy,” which…
On May 5, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC“) issued General License No. 58 (“GL 58“), authorizing transactions ordinarily incident to the provision of certain services in…
On May 18, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 134C (“GL 134C”), further extending the temporary authorization for certain transactions involving crude oil and petroleum…
Vigilant Visitation Opportunities
We will be out and about at different trade and compliance related conferences around the country! We would love for you to come to say hello, so we can get to know you better! You can also connect with us at: https://vigilantgts.com/ or through our socials, on Facebook and LinkedIn!
Where we will be:
ICPA Canada Conference, June 7 – 10
Toronto, Ontario Canada
Jamie Adams will be presenting, again, on the importance of US and CA Customs Entry and Broker Audits and also presenting on Duty Mitigation Strategies. The choir will also be singing, and we are looking to increase in numbers. You do receive a 33% discount for singing with us.
CBP Trade and Cargo Security Summit, (Rescheduled to September, 8-10, 2026)
Dallas, TX
Jamie Adams will be attending sessions and happy to connect with you.
ICPA Global Trade Pathways Conference (Fall), September 13, 2026
Grapevine, TX
Vigilant will be a sponsor and you can visit us at our booth. Jamie Adams will be presenting and leading the choir.
ICPA Global Trade Insights Conference (Fall), September 29 – October 1, 2026
Dublin, Ireland
Jamie Adams will be moderating a panel on US Tariff Updates and Mitigation Strategies.
TRADE BUZZ – Powered by Vigilant GTS
Joe Burks has moved on to a new position at a new company, and he has graciously handed the reigns of Trade Buzz to Jamie Adams. We posted a video this week regarding the benefits and risks of Artificial Intelligence and how we recommend working internally to help it be the most beneficial coupled with human oversight – https://vigilantgts.com/clean-data-smarter-ai-results-hb/
Check back with us every Tuesday as we will be publishing new quick topic videos every week.
You can see the library of all our videos on our website at: https://vigilantgts.com/webinars/