THE VIGILANT VIGIL – 21ST 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 latest edition of the Vigilant Vigil.
I have to admit something.
For a long time—even after all the tariff announcements over the past year—I secretly believed we would eventually return to “normal.” I thought many of these actions would primarily serve as negotiating tools. Countries would posture, agreements would be reached, tariffs would come down, and global trade would settle back into something resembling the environment we all knew.
I don’t believe that anymore.
This is the new normal.
And if this week has taught us anything, it is that trade compliance is no longer a support function quietly operating in the background. It has become one of the most strategic disciplines inside every importing and exporting organization.
Just look at what has happened over the past few days:
- New tariff threats against Canada under Section 338.
- New tariffs announced on Brazil.
- Section 122 scheduled to expire—with the trade community waiting to see what comes next.
- Anticipation of sweeping new Section 232 and Section 301 actions that could arrive with little time for industry to prepare.
- Continued rollout of the IEEPA refund process, with Phase 3 expected to require litigation before the Court of International Trade for many importers.
- The European Union announcing one of its largest sanctions packages against Russia.
- New discussions surrounding pharmaceutical tariffs and reshoring.
- Continued investment by the U.S. government—billions of dollars—in AI-driven enforcement technologies.
- And perhaps most concerning of all, enforcement statistics showing a dramatic shift from CBP asking questions… to simply taking action.
That last point deserves our attention.
For years, many of us expected a CF-28 before serious enforcement followed. Increasingly, the data suggests CBP already believes the entry itself tells the story. When AI can compare your declaration against decades of ACE data, thousands of prior entries, and hundreds of other data points in seconds, the agency doesn’t necessarily need to ask what happened. It often believes it already knows.
That should change the way every importer thinks about compliance.
At the same time, the rest of the world is responding. Canada is implementing reciprocal procurement restrictions. Europe continues expanding sanctions. Countries are reassessing long-standing trade relationships. Supply chains are shifting. Politics, economics, national security, and trade policy are becoming increasingly intertwined.
This isn’t temporary turbulence.
This is the operating environment.
For years, trade professionals have joked that we were the “department in the basement”—the people everyone forgot about until something went wrong. Those days are over. Executive leadership is beginning to realize that tariff strategy, origin, valuation, classification, forced labor compliance, sanctions, export controls, recordkeeping, and AI-driven enforcement now carry financial and legal consequences that can affect the entire enterprise.
That means trade organizations must evolve as well. Budgets need to reflect today’s risks. Teams need additional support. Technology must move beyond manual spreadsheets and sampling. Trusted brokers, freight forwarders, software providers, consultants, attorneys, and managed services partners all become part of a broader compliance ecosystem. No single person can realistically keep pace with everything anymore.
If there is one takeaway from this week’s Vigil, it is simply this:
Stop waiting for things to “settle down.”
Prepare for this to be the new reality.
Build stronger processes. Audit more aggressively. Invest in your people. Embrace technology. Surround yourself with good partners. Most importantly, continue learning. Because while none of us knows exactly what tomorrow’s headlines will bring, we can be confident there will be more headlines.
And finally—a reminder I probably need more than anyone reading this.
Take care of yourself.
Trade compliance is becoming more demanding every week. The regulations will still be here tomorrow. The Federal Register will still publish. CSMS messages will continue arriving. There will always be another webinar, another tariff, another Executive Order, another investigation.
Next week I’ll be stepping away for a few days to spend time camping in the Canadian Rockies with my husband. No laptops. No webinars. Just mountains, wildlife, fresh air, and hopefully a chance to let my brain think about something other than Chapter 99 tariff numbers.
I encourage you to find your own version of that.
We’ll all need it—because this marathon isn’t ending anytime soon.
Jamie Adams, LCB, CCS
Director of Global Compliance Solutions
Vigilant Global Trade Services
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.**
Proclamations
Alcoholic Beverages; Imposing Additional Duties To Offset Canadian Discrimination Against U.S. Commerce (Proc. 11046)
| FR Document: 2026-14991 Citation: 91 FR 46639 |
PDF Pages 46639-46652 (14 pages) Permalink |
| Abstract: [Not available] | |
Aluminum, Imports Into U.S.; Further Strengthening Actions To Adjust (Proc. 11045)
| FR Document: 2026-14990 Citation: 91 FR 46635 |
PDF Pages 46635-46638 (4 pages) Permalink |
| Abstract: [Not available] | |
Dairy; Imposing Additional Duties To Offset Canadian Discrimination Against U.S. Commerce (Proc. 11047)
| FR Document: 2026-14992 Citation: 91 FR 46653 |
PDF Pages 46653-46661 (9 pages) Permalink |
| Abstract: [Not available] | |
Motor Vehicles; Imposing Additional Duties To Offset Canadian Discrimination Against U.S. Commerce (Proc. 11048)
| FR Document: 2026-14997 Citation: 91 FR 46663 |
PDF Pages 46663-46688 (26 pages) Permalink |
| Abstract: [Not available] | |
Executive Orders
Critical Materials; Efforts To Secure U.S. Defense Supply Chains and Ensure Domestic Acquisition (EO 14415)
| FR Document: 2026-15003 Citation: 91 FR 46693 |
PDF Pages 46693-46697 (5 pages) Permalink |
| Abstract: [Not available] | |
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 # 69302472 – GUIDANCE: Section 301 Duties on Certain Products from Brazil
The purpose of this message is to provide guidance regarding the Office of the United States Trade Representative’s action imposing 25 percent tariffs on all imports of Brazil, with certain exemptions, under section 301 of the of the Trade Act of 1974, effective July 22, 2026. See 91 FR 45516…
CSMS # 69302472 – GUIDANCE: Section 301 Duties on Certain Products from Brazil
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
Determination:
Brazil’s Acts, Policies, and Practices Related to Digital Trade and Electronic Payment Services
| FR Document: 2026-14542 Citation: 91 FR 45516 |
PDF Pages 45516-45615 (100 pages) Permalink |
| Abstract: The United States Trade Representative (Trade Representative) has determined under Section 301(b) and Section 304(a) of the Trade Act of 1974, as amended (Trade Act), that certain of Brazil’s acts, policies, and practices at issue in this investigation are actionable and that action by the United States is appropriate. In accordance with the specific direction of the President, the Trade Representative is taking action by imposing 25 percent tariffs on all imports of Brazil, with certain… | |
Notices
Sanctions Action*
| FR Document: 2026-14706 Citation: 91 FR 46227 |
PDF Pages 46227-46238 (12 pages) Permalink |
| Abstract: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has removed from OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List) the names of certain persons whose property and interests in property had been blocked pursuant to Hong Kong sanctions authorities. Additionally, OFAC has transferred names of persons who remain sanctioned under the Hong Kong Autonomy Act… | |
*This is just one of the 4-5 sanctions actions reports taken over the past week.
News from other esteemed sources:
THOMPSON/HINE
DOJ and DHS Release Trade Fraud Enforcement Resource Guide, Signaling Heightened Enforcement
On July 14, 2026, the Department of Justice (DOJ) and Department of Homeland Security (DHS) jointly issued A Resource Guide to Trade Fraud Enforcement (the “Resource Guide”) through the newly established Trade Fraud Task Force, which includes DOJ’s National Fraud Enforcement Division, DHS Homeland Security Investigations (HSI), and U.S. Customs and Border Protection (CBP).
View the entire bulletin in HTML format.
View the entire bulletin in PDF format.
BAKER/MCKENZIE
| US Proposes Additional 50% Tariffs on Canadian Origin Goods, Effective August 19
On Monday, July 20, President Trump signed three Proclamations invoking Section 338 of the Tariff Act of 1930 to impose 50% tariffs on certain Canadian origin goods (Section 338 Tariffs). These tariffs are scheduled to enter into force at 12:01 AM… |
| Singapore: Enforcement Action Against False Origin Declaration
On 11 June 2026, Singapore Customs issued a media release announcing that three Singapore-registered companies and three individuals had been charged with offences relating to false declarations, false statements and incorrect trade descriptions…
|
USCIS
Understanding President Trump’s New Tariffs on Canadian Imports
Critical Questions by Christopher Gundermann, Hugh Grant-Chapman, and Diego Marroquín Bitar
On July 20, President Trump formally invoked Section 338 of the Tariff Act of 1930 for the first time to impose 50 percent duties against a significant range of Canadian products. Our experts explain the statute and its global implications.
Understanding President Trump’s New Tariffs on Canadian Imports
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
We posted a video this week regarding mergers and acquisitions and the risks for not engaging the trade compliance team early enough in the process – https://vigilantgts.com/uncover-hidden-trade-risks-before-merging-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/