THE VIGILANT VIGIL – 24th 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:
KNOW YOUR… EVERYTHING?
For more than 30 years in export compliance, I’ve had one concept drilled into me: KYC, Know Your Customer. Know the customer, end user, end use and destination. Screen the parties. Understand the product. Identify the red flags. Document the decision. BIS actually maintains formal “Know Your Customer” guidance under the EAR, so this isn’t merely an old trade-nerd mantra. It is baked into the way export compliance professionals are expected to think.
But lately I’ve been wondering whether KYC is enough.
Trade enforcement is changing dramatically. DOJ announced last month that its Trade Fraud Task Force had surpassed $1 billion in civil and criminal recoveries, penalties, forfeitures and publicly charged losses in less than one year. In the same announcement, DOJ reported that CBP had already assessed more than $2.1 billion in commercial trade penalties during FY2026. We are seeing False Claims Act cases involving origin and ADD/CVD, criminal trade-fraud proceedings and increasingly sophisticated use of data in government investigations.
For years, we talked about “Trust, but verify.” I think we need to reverse it. In today’s environment, VERIFY, then trust.
And that applies to a lot more than customers. We need to Know Our Suppliers and Supply Chains (KYS/KYSC) because forced labor, origin, valuation, ADD/CVD, USMCA and today’s increasingly complicated tariffs require evidence, not assumptions. We need to Know Our Data (KYD) because government agencies have increasingly sophisticated access to the information we’ve submitted, and if knowledge is power, data is a superpower. It would probably be wise to know our own data at least as well as the people auditing it.
We also need to Know Our Partners (KYP) because brokers, forwarders, consultants, attorneys and technology providers may perform work on our behalf, but we remain responsible for understanding what is being done in our name. We need to Know Our Transactions (KYT) because perfect master data doesn’t help much if the wrong HTS, origin, value or Chapter 99 code ends up on the actual entry. Longtime Vigil readers know my answer to that one: audit, audit, audit. And don’t forget the oddball transactions outside your normal process, because those have an uncanny ability to become the ones everyone wishes they had noticed earlier.
Perhaps one of the more uncomfortable additions is Know Your Enforcers (KYE). I have encountered companies that treat CBP, BIS and other government agencies a little like Voldemort: don’t say the name, don’t make eye contact and perhaps they won’t notice us. I have never been convinced that is the best strategy.
Some of the most productive experiences of my career have involved actually meeting with government officials and teaching them about the products, suppliers and processes they were regulating. In more than one instance, persistent clearance problems disappeared after we simply sat down and helped regulators understand our business. Sometimes their problem is also a knowledge problem.
That doesn’t mean inviting the government in for coffee every Tuesday. It means knowing your Center of Excellence and Expertise (CEE), understanding what CBP, BIS, OFAC, DOJ, CBSA and other agencies are focused on, reading their enforcement cases and participating appropriately in programs and events where you can learn directly from regulators. CBP’s CTPAT program, for example, specifically includes access to a Supply Chain Security Specialist and priority consideration at CBP’s industry-focused Centers among its identified benefits.
Finally, we need to Know Our Future (KYF). What acquisitions is your company considering? Where will Procurement source next? What is Engineering developing? Where does leadership want to expand? What geopolitical, economic, technological and regulatory developments may affect those plans? Trade Compliance needs to be involved in those conversations before the contracts are signed and the shipments are sitting at the border.
That also means accepting that technology is coming whether we are comfortable with it or not. Many of us “old folks” in trade remember having the giant paper HTS sitting on the desk. We survived automation. We survived GTM systems. We will survive AI too. The important question isn’t whether we use these tools, but how responsibly we use them while retaining the human expertise, skepticism and oversight that a good compliance program requires.
I went much deeper into this subject in a separate article this week because, once I started writing, my little foreword became something closer to a manifesto. You can read the full piece here:
https://vigilantgts.com/knowledge-is-power-it-may-be-time-to-redefine-kyc/
There is one conclusion from the larger article that I do want to leave here, however. Maybe we shouldn’t abandon KYC. Maybe we simply need to redefine it.
KYC used to mean KNOW YOUR CUSTOMER. In 2026, perhaps it needs to mean KNOW YOUR COMPLIANCE: know your customers, suppliers, supply chains, data, partners, transactions, enforcers and future. Know where your risks are, know what the government knows and, perhaps most importantly, know what you don’t know.
None of us can possibly do all of that alone. That’s one reason I’m particularly looking forward to the ICPA Global Trade Pathways Conference on September 13 in Grapevine, Texas. Vigilant will be sponsoring, I’ll be presenting and, yes, apparently leading the choir again. Our professional networks aren’t merely social anymore. The attorneys, consultants, technology providers, regulators and fellow trade nerds we learn from have become part of our compliance infrastructure.
So maybe that is the real message for Vigil No. 24: Knowledge is power. Data is a superpower. Verify, then trust. And KNOW YOUR COMPLIANCE.
Stay vigilant.
Jamie Adams
Director of Global Compliance Solutions
Vigilant Global Trade Services
In this volume, we will explore:
- 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.**
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 # 69519766 – Updated Guidance #4: Implementation of Jones Act Waiver issued to the Department of War, dated March 17, 2026
The waiver will be extended for an additional 90-day period commencing on August 17, 2026, at 12:00 a.m. Eastern Time. CBP has determined that to be compliant with the extended waiver, any covered product must be loaded onboard the relevant vessel before the deadline expires at 11:59 pm Eastern Time on Sunday, November 15, 2026. With notice of this extension, CBP is also providing an updated list of potentially covered products (attached) as of August 17, 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
Proclamations
Polysilicon and Derivatives, Imports Into U.S.; Adjustment (Proc. 11052)
| FR Document: 2026-16400 Citation: 91 FR 51975 |
PDF Pages 51975-51987 (13 pages) Permalink |
| Abstract: These actions are based on advice and information I received from the Secretary of Commerce (Secretary) in a report transmitted to me within the past 90 days detailing the findings of his investigation under section 232 of the Trade Expansion Act of 1962, as amended, 19 U.S.C. 1862 (section 232), into the effects of imports of polysilicon and its derivative products on the national security of the United States. | |
Rules
Implementation of the Administrative False Claims Act
| FR Document: 2026-16207 Citation: 91 FR 51386 |
PDF Pages 51386-51391 (6 pages) Permalink |
| Abstract: This rule would establish updated, procedural regulations implementing the Administrative False Claims Act (AFCA) at the Department of State. | |
Agency Information Collection Activities; Proposals, Submissions, and Approvals:
Aluminum Import Monitoring and Analysis System
| FR Document: 2026-16473 Citation: 91 FR 52290 |
PDF Page 52290 (1 page) Permalink |
| Abstract: Comments were received during the 60-day notice period from the Aluminum Association. Those comments indicated that import license program was valuable, has utility and has reasonable and modest burden hours. The suggestions to enhance the utility of the data collected fall outside of the current scope of the renewal of the licensing system. No further actions to minimize the reporting burden hours were suggested. | |
News from other esteemed sources:
BAKER/MCKENZIE
US: President Trump Imposes New Section 232 Measures on Polysilicon Products
On August 6, 2026, President Trump issued a proclamation under Section 232 of the Trade Expansion Act of 1962, establishing new import restrictions on polysilicon and a range of downstream products. This is the result of a process that started in…
Read more…
On July 23, 2026, the Government of Canada began inviting input from stakeholders on the administration of the tariff-rate quotas (TRQs) on certain steel goods. These tariff-rate quotas have been in place since June 27, 2025 and were most recently…
Read more…
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.
ICPA Mexico Conference, November 3 – November 5, 2026
Mexico City, Mexico
Jamie Adams will be moderating a panel on USMCA Enforcement and Verifications.
TRADE BUZZ – Powered by Vigilant GTS
Trade never stands still—and neither do we.
Every Tuesday, we publish a new Trade Buzz episode highlighting timely developments in customs, tariffs, export controls, sanctions, compliance, and global trade. Our goal is simple: provide practical, easy-to-understand insights that help you stay informed and prepared.
This week’s topic: Tariffs on top of tariffs, stacked on tariffs… with a tariff cherry on top. With today’s increasingly complicated tariff environment, understanding classification, country of origin, tariff stacking, exemptions, and what was actually filed on your entries is critical. Good tariff management isn’t just about compliance—it can help protect your bottom line.
🎥 Watch the latest episode:
https://youtu.be/0dx1NTt2A4s?si=UqVhcPxpQCoflIBQ
📖 Read the accompanying Trade Buzz blog:
https://vigilantgts.com/tame-tariffs-protect-your-bottom-line-hb/
Missed a previous episode? Browse the complete Trade Buzz library at: