THE VIGILANT VIGIL – 14TH 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 fourteenth edition of the Vigilant Vigil.
Well, trade nerds, it finally happened.
For months—perhaps years—many of us in the trade compliance community have been watching the signs. We pointed to the explosion of tariffs, increased UFLPA enforcement, the growth of whistleblower programs, the expansion of ACE and CAPE functionality, heightened scrutiny of AI-driven compliance tools, and the government’s growing expectation that importers exercise genuine reasonable care over every aspect of their customs activities. We talked about “girding your loins.” We talked about getting your house in order. We talked about auditing entries, documenting decisions, and strengthening controls before the government forced the issue.
Some listened.
Many did not.
Now the White House has issued an Executive Order on strengthening customs enforcement, and whether one agrees with every aspect of the policy or not, one thing is unmistakably clear: the federal government has formally declared customs enforcement a priority. What many trade professionals viewed as trends, forecasts, or educated predictions have now been memorialized in black and white with a Presidential signature at the bottom of the page.
This is not an “I told you so” moment. Quite frankly, I wish many of us had been wrong.
Instead, I view this as a final warning shot across the bow.
The Executive Order itself speaks extensively about fentanyl, illicit trade, national security concerns, and bad actors operating outside the law. However, trade professionals understand that enforcement authorities rarely build tools for only one purpose. Increased scrutiny of customs activities inevitably creates increased scrutiny across the entire compliance spectrum, including classification, valuation, country of origin, tariff applicability, free trade agreement qualification, recordkeeping, broker oversight, supply chain due diligence, and reasonable care obligations.
In many respects, we have already seen a preview.
The CAPE refund process provided a real-world example of what happens when organizations prioritize speed over preparation. Compliance teams throughout the country asked for time to audit entries before submission. Many were told there was no budget, no time, or no business justification. The result has been predictable: rejected claims, entries placed on hold, refund delays, CF-28s, CF-29s, and difficult conversations with leadership teams wondering why anticipated recoveries have not materialized.
The lesson was never really about refunds.
The lesson was about readiness.
That is why I would encourage every importer, exporter, customs broker, freight forwarder, and compliance professional reading this edition to spend time reviewing the Executive Order directly. Do not rely solely on summaries, webinars, LinkedIn posts, or secondhand interpretations. Read the source document yourself and ask a few simple questions:
- Are our policies and procedures current and defensible?
- Are we auditing our entries frequently enough?
- Do we have adequate oversight of our service providers?
- Is our documentation sufficient to support our decisions?
- Could we confidently defend our compliance program during an audit or investigation?
The good news is that the government is not implementing all of this tomorrow. There is still time to prepare. The bad news is that time moves remarkably quickly, and many organizations are already behind where they should be.
Trade professionals often complain that regulatory changes arrive without warning. This time, we have been given one.
The trade nerds have been warning about increased enforcement for quite some time. The Executive Order does not create those concerns—it validates them.
The question now is not whether change is coming.
The question is whether we will finally act before we are forced to react.
Let’s stay vigilant.
Jamie Adams, LCB, CCS
Director of Global Compliance Solutions at Vigilant GTS
In this volume, we will explore:
- Updates from the President
- Updates to the Federal Registry, for both policy and lots of sanctions actions
- 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.**
Presidential Updates
**The following are updates from the president, or office of the president, by way of CBP and/or the Federal Register. As such, they may or may not be officially lawful or enforceable under the law, as of this posting.**
White House issues new executive order to strengthen customs enforcement, protecting U.S. consumers and businesses
06/03/2026 02:42 PM EDT
WASHINGTON—Today, President Donald Trump signed Executive Order “Strengthening Customs Enforcement,” empowering U.S. Customs and Border Protection with a comprehensive set of tools to safeguard American consumers, businesses, and revenue while…
Aluminum, Steel, and Copper Imports Into U.S.; Further Adjustment to Tariff Regimes (Proc. 11032)
| FR Document: 2026-11314 Citation: 91 FR 34085 |
PDF Pages 34085-34141 (57 pages) Permalink |
| Abstract: Based on the Secretary of Commerce’s (Secretary) monitoring and consultation with other senior officials, among other things, the Secretary has provided me information, opinions, and recommendations regarding the tariff regimes imposed…In particular, the Secretary recommended that [we] expand the category of derivative products… | |
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
Proposed Rules
Export-Import Bank (extends to ALL government departments)
Regulation for Federal Financial Assistance
| FR Document: 2026-10817 Citation: 91 FR 32198 |
PDF Pages 32198-32305 (108 pages) Permalink |
| Abstract: The Office of Management and Budget (OMB) proposes to revise the Guidance for Federal Financial Assistance to improve government- wide policies and requirements related to the management of grants, cooperative agreements, and other forms of assistance. OMB is proposing revisions that would improve transparency, accountability, and oversight for Federal awards across the Federal Government. This includes ensuring that American tax dollars are not wasted or misused, activities performed under… | |
Initiation of Section 301 Investigations
Vietnam’s Acts, Policies, and Practices Related to Intellectual Property Protection and Enforcement
| FR Document: 2026-11043 Citation: 91 FR 33285 |
PDF Pages 33285-33287 (3 pages) Permalink |
| Abstract: Pursuant to section 182(a)(2) of the Trade Act of 1974, as amended (Trade Act), the U.S. Trade Representative (Trade Representative) identified Vietnam as a priority foreign country due to Vietnam’s denial of adequate and effective protection of intellectual property (IP) rights and its denial of fair and equitable market access to persons that rely on IP protection. Pursuant to section 302(b)(2) of the Trade Act, the Trade Representative is initiating a Section 301 investigation of the acts,… | |
Investigations; Determinations, Modifications, and Rulings, etc.
Prestressed Concrete Steel Wire Strand from Brazil, India, Japan, Mexico, the Republic of Korea, and Thailand
| FR Document: 2026-11266 Citation: 91 FR 33689 |
PDF Pages 33689-33690 (2 pages) Permalink |
| Abstract: As a result of the determinations by the U.S. Department of Commerce (Commerce) and the U.S. International Trade Commission (ITC) finding that revocation of the antidumping duty (AD) orders on prestressed concrete steel wire strand (PC strand) from Brazil, India, Japan, Mexico, the Republic of Korea (Korea), and Thailand and the countervailing duty (CVD) order on PC strand from India would likely lead to the continuation or recurrence of dumping, countervailable subsidies, and material injury… | |
Tin Mill Products from China, Taiwan, and Turkey
| FR Document: 2026-10647 Citation: 91 FR 32090 |
PDF Pages 32090-32091 (2 pages) Permalink |
| Abstract: the United States International Trade Commission determines, pursuant to the Tariff Act of 1930, that there is a reasonable indication that an industry in the United States is materially injured by reason of imports of tin mill products from China, Taiwan, and Turkey…are alleged to be sold in the United States at less than fair value (“LTFV”) and imports of the subject merchandise from China that are alleged to be subsidized by the government of China. | |
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 importance of knowing your suppliers and mapping your supply chain – https://vigilantgts.com/uncover-supplier-risks-safeguard-your-brand-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/