THE VIGILANT VIGIL – 16TH EDITION

June 19, 2026

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 sixteenth edition of the **Vigilant Vigil**.

I’ll be honest with you.

I sat down to write this week’s foreword after two weeks of travel, conference presentations, client meetings, delayed flights, hotel rooms that all start to look the same, and more caffeine than any physician would likely recommend. And for the first time in a long while, I found myself staring at a blank page wondering what exactly I wanted to say.

Not because there isn’t enough happening.

Because there is too much happening.

Then it hit me.

The theme isn’t tariffs.

The theme isn’t IEEPA.

The theme isn’t forced labor.

The theme isn’t sanctions.

The theme isn’t export controls.

The theme is enforcement.

Everything seems to be enforcement right now.

As I reviewed this week’s content, the pattern became impossible to ignore. CBP released new forced labor enforcement guidance. CBP is actively encouraging trade violation reporting and EAPA allegations. New Withhold Release Orders continue to emerge. China is expanding export controls. The U.S. government continues updating military company lists. Customs enforcement remains a central focus of the administration. IEEPA refund reviews continue. Section 232 and Section 301 actions continue. And last week’s Executive Order on customs enforcement still hangs over the industry like a thundercloud.

Individually, none of these developments are necessarily surprising.

Collectively, they paint a very clear picture.

Governments around the world are becoming more active, more assertive, and more willing to investigate, verify, challenge, and enforce.

And if I’m being completely candid, that makes me a little anxious.

Not because compliance is impossible.

Not because businesses cannot adapt.

But because many organizations still seem to believe we are operating in the same environment we were five or ten years ago.

We aren’t.

The old model of “our broker handles that” or “we’ve never had a problem before” feels increasingly outdated. Today, governments want documentation. They want proof. They want traceability. They want accountability. Increasingly, they want to know not only what happened, but why it happened, who approved it, and whether you can defend it.

That’s a very different environment than many of us grew up in professionally.

The good news is that compliance is still achievable.

Reasonable care is still the standard.

Strong policies, sound procedures, quality audits, effective training, and good partners still go a very long way toward mitigating risk.

But the days of passive compliance seem to be fading quickly.

This week’s Vigil contains several examples of that trend. I encourage you to read them carefully and think about what they mean collectively, not just individually.

Because while tariffs may grab the headlines, enforcement is increasingly becoming the story.

And whether we like it or not, it appears that story is just getting started.

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, announcements and policy
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 # 68927213 – Launch of CBP’s Forced Labor Enforcement Operational Guidance for Importers

U.S. Customs and Border Protection (CBP) is excited to announce the release of its new Forced Labor Enforcement Operational Guidance for Importers. This updated document provides a consolidated overview of the three authorities CBP uses to prevent the importation of goods produced with forced labor into the United States in a single, accessible document:

CSMS # 68927213 – Launch of CBP’s Forced Labor Enforcement Operational Guidance for Importers

CSMS # 68902435 – Final Reminder: Register for U.S. Customs and Border Protection’s June Trade Enforcement Webinars

This is a final reminder to register for U.S. Customs and Border Protection’s (CBP) free quarterly trade enforcement webinars scheduled for June 23 and 25. These essential sessions are designed to empower the public with the knowledge to effectively report suspected trade violations and file Enforce and Protect Act (EAPA) allegations with CBP.

June Webinar Dates

Please click on the direct links below to register for individual webinars:

Trade Violations Reporting (TVR) Webinar - Tuesday, June 23, 2026, at 1:30 p.m. ET

Enforce and Protect Act (EAPA) Webinar – Thursday, June 25, 2026, at 1:00 p.m. ET

Registration is free and open to everyone, but you must register to attend.

CSMS # 68963141 – Withhold Release Order (WRO) on Copper and Copper Products Manufactured in Serbia, by Serbia Zijin Copper D.O.O.

U.S. Customs and Border Protection (CBP) issued a Withhold Release Order (WRO) against copper and copper products manufactured in Serbia by Serbia Zijin Copper D.O.O. (Serbia Zijin). Effective immediately,

CSMS # 68963141 – Withhold Release Order (WRO) on Copper and Copper Products Manufactured in Serbia, by Serbia Zijin Copper D.O.O.

CSMS # 68966469 – ACE Portal: New Tools and Automation for Account Management

U.S. Customs and Border Protection (CBP) recently introduced tools and automation to streamline aspects of account management for the Automated Commercial Environment Secure Data Portal (ACE Portal).

CSMS # 68966469 – ACE Portal: New Tools and Automation for Account Management

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

Agency Information Collection Activities; Proposals, Submissions, and Approvals:

Procedures for Submissions by Certain Steel and Aluminum Producers Committing to New U.S. Steel or Aluminum Production to Obtain Tariff Adjustments Under Proclamation 10984

FR Document: 2026-12343
Citation: 91 FR 36803

PDF Pages 36803-36804 (2 pages)
Permalink

Abstract: The Department of Commerce, in accordance with the Paperwork Reduction Act of 1995 (PRA), invites the general public and other Federal agencies to comment on proposed, and continuing information collections, which helps us assess the impact of our information collection requirements and minimize the public’s reporting burden. The purpose of this notice is to allow for 60 days of public comment preceding submission of the collection to OMB.

Hearings, Meetings, Proceedings, etc.:

Commercial Customs Operations Advisory Committee

FR Document: 2026-12091 Citation: 91 FR 36154	PDF Pages 36154-36155 (2 pages) Permalink
Abstract: The Commercial Customs Operations Advisory Committee (Committee) will hold its quarterly meeting on Wednesday, July 15, 2026, in Washington, DC. The meeting will be open to the public via webinar only.

News from other esteemed sources:

BAKER/MCKENZIE

China Expands Export Controls on Precursor Chemicals for Specified Destinations
06/16/2026

On 22 May 2026, China’s Ministry of Commerce (MOFCOM), together with the Ministry of Public Security, the Ministry of Emergency Management, the General Administration of Customs, and the National Medical Products Administration, jointly issued…

THE VIGILANT VIGIL – 16TH EDITION

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