THE VIGILANT VIGIL – 15TH 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 fifteenth edition of the Vigilant Vigil.
First, my apologies for this edition being a day late. Between airports, client meetings, conference sessions, delayed flights, and the general chaos that seems to accompany modern business travel, the week got away from me.
Last week I had the pleasure of attending the ICPA Canada Conference in Toronto. It was a fantastic event. The choir proudly sang O Canada, I had the opportunity to present on duty mitigation and broker audits, and there were excellent discussions on valuation, classification, origin determination, sanctions, enforcement, CARM, trade policy, and just about every other topic keeping compliance professionals awake at night these days.
But as I sat on the flight home, I realized something interesting.
The thing that stuck with me most wasn’t a particular presentation.
It wasn’t a new regulation.
It wasn’t a new tariff.
Honestly, it wasn’t even the conference content.
It was the conversations.
You see, when you’re sitting in your office, buried under emails, meetings, audits, tariff updates, sanctions alerts, executive questions, broker issues, system challenges, and whatever fresh surprise the government has decided to hand us this week, it’s easy to start thinking everyone else has it figured out.
Maybe it’s just me.
Maybe everyone else knows exactly what they’re doing.
Maybe everyone else’s compliance program is perfect.
Then you spend three days with nearly 300 trade professionals and discover something rather comforting:
Nobody has this all figured out.
Not the importers.
Not the brokers.
Not the attorneys.
Not the consultants.
Not the software providers.
Not even the government, if we’re being completely honest.
Everyone is trying to make sense of an environment that seems to become more complicated every single week.
One session would focus on valuation. The next on sanctions. Then trade policy. Then enforcement. Then CARM. Then origin. Then customs audits. Then AI. Then geopolitical risks. Then back to tariffs again.
By the end of the conference, I wasn’t struck by how different everyone’s challenges were.
I was struck by how similar they were.
Whether someone worked for a Fortune 100 manufacturer, a customs broker, a law firm, a software company, or a government agency, the themes were remarkably consistent.
How do we keep up?
How do we manage the risk?
How do we prepare for what’s coming next?
How do we help our organizations navigate all this uncertainty?
Those are the same questions all of us are asking.
And strangely enough, I found that reassuring.
One of my favorite parts of ICPA has always been that it reminds me this industry is filled with incredibly smart, generous people. Some of my closest friends, mentors, former colleagues, business partners, and even competitors were in attendance. Many of us now work for different companies, sell competing services, or sit on opposite sides of a transaction. Yet we still greet each other with hugs, stories, laughter, and a genuine willingness to help.
That’s pretty special.
In a profession that often feels overwhelming, it’s easy to forget that we’re part of a community.
A very good one.
So if you’re feeling buried under the weight of tariffs, sanctions, enforcement initiatives, system changes, court decisions, geopolitical uncertainty, and the never-ending stream of trade updates, let me offer a thought that Toronto reminded me of:
You’re not behind.
You’re not failing.
You’re not the only one trying to figure this out.
You’re just working in global trade in 2026.
And there are a few hundred thousand of us doing exactly the same thing.
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
- CSMS updates
- Updates to the Federal Registry, for both policy and product
- 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.**
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.**
Customs Enforcement; Strengthening Efforts (EO 14411)
| FR Document: 2026-11595 Citation: 91 FR 35125 |
PDF Pages 35125-35129 (5 pages) Permalink |
| Abstract: …in consultation with the heads of relevant agencies, the Secretary shall enhance transparency in customs by taking steps to establish various requirements, standards, and practices consistent with the policy of this order. These measures shall include requiring periodic… | |
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 # 68855869 – GUIDANCE: Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States
The purpose of this message is to provide guidance on the implementation of the June 1, 2026, Proclamation, “Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States.”
CSMS # 68888585 – Harmonized System Update (HSU) 2613
Harmonized System Update (HSU) 2613 was created on June 7, 2026, and contains 23 harmonized tariff records and 54 automated broker interface (ABI) records.
This HSU contains the Section 232 tariff adjustments for imports of aluminum, steel and copper into the U.S.
CSMS # 68888585 – Harmonized System Update (HSU) 2613
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
Foreign Trade Regulations; Correction
| FR Document: 2026-11688 Citation: 91 FR 35383 |
PDF Pages 35383-35384 (2 pages) Permalink |
| Abstract: On March 30, 2026, the Bureau of the Census (Census Bureau) published a final rule in the Federal Register entitled ” Streamlining the Census Bureau’s Foreign Trade Regulations”, which became effective on March 30, 2026. Subsequent review of the final rule in the Federal Register identified an error necessitating corrective action. Accordingly, this final rule issues a non-substantive correction to the Foreign Trade Regulations. | |
Determination:
Actions in Section 301 Investigations of Acts, Policies, and Practices of Various Economies Related to the Failure to Impose and Effectively Enforce a Prohibition on the Importation of Goods Produced with Forced Labor
| FR Document: 2026-11296 Citation: 91 FR 34272 |
PDF Pages 34272-34345 (74 pages) Permalink |
| Abstract: On March 12, 2026, the United States Trade Representative (Trade Representative) initiated 60 investigations related to the failure of various economies to impose and effectively enforce a prohibition on the importation of goods produced with forced labor. The Trade Representative has determined that 54 of the investigated economies have failed to impose and effectively enforce a forced labor import prohibition. The Trade Representative has determined that six of the investigated economies… | |
Request for Comments:
Mechanism to Promote Reciprocal Managed Trade with China
| FR Document: 2026-11291 Citation: 91 FR 34269 |
PDF Pages 34269-34272 (4 pages) Permalink |
| Abstract: USTR invites comments from interested parties to inform the development of negotiations with China aimed at optimizing bilateral trade in non-sensitive products in order to promote reciprocity and balance in the U.S.-China trade relationship. In particular, comment is sought on the types of non-sensitive products that would benefit from favorable tariff modifications by both sides, and considerations around the design of a new government-to-government mechanism–a U.S.-China Board of… | |
Investigations; Determinations, Modifications, and Rulings, etc.:
Common Alloy Aluminum Sheet from Bahrain, Brazil, Croatia, Egypt, Germany, India, Indonesia, Italy, Oman, Romania, Serbia, Slovenia, South Africa, Spain, Taiwan, and Turkey
| FR Document: 2026-11829 Citation: 91 FR 35706 |
PDF Page 35706 (1 page) Permalink |
| Abstract: The Commission hereby gives notice that it will proceed with full reviews pursuant to the Tariff Act of 1930 to determine whether revocation of the countervailing duty orders on common alloy aluminum sheet (“CAAS”) from Bahrain, India, and Turkey and the revocation of the antidumping duty orders on CASS from Bahrain, Brazil, Croatia, Egypt, Germany, India, Indonesia, Italy, Oman, Romania, Serbia, Slovenia, South Africa, Spain, Taiwan, and Turkey would be likely to lead to continuation or… | |
News from other esteemed sources:
CSIS/TRADE GUYS
| China’s Retaliatory Tariffs, Section 301 Authorities, and Tariff Refund Litigation |
| On this episode of the Trade Guys, Bill and Scott discuss the impacts of Chinese retaliatory tariffs on U.S. agricultural and other trade, the Trump administration’s continued efforts to implement Section 301 tariffs, and the ongoing tariff refund litigation. |
THOMPSON/HINE
President Trump Modifies Section 232 Tariffs on Aluminum, Copper and Steel Imports
By Scott E. Diamond**, David M. Schwartz, Francesca M.S. Guerrero & Samir D. Varma on June 10, 2026
On June 1, 2026, President Donald Trump issued a Proclamation amending the rates, scope, and administration of the Section 232 tariff regimes for aluminum, steel, and copper and their derivative products.
President Trump Modifies Section 232 Tariffs on Aluminum, Copper and Steel Imports | SmarTrade
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:
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 of ICPA Membership for your compliance program and your long-term career – 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/