THE VIGILANT VIGIL – 25th 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:
Last week, I may have created a monster.
I took the familiar export compliance concept of KYC: Know Your Customer and suggested that perhaps our current trade environment requires an entire family of KYXs: Know Your Supplier, Supply Chain, Data, Partners, Transactions, Enforcers and Future. Ultimately, I suggested that KYC itself might deserve a new definition: KNOW YOUR COMPLIANCE.
Apparently, I didn’t know all my KYXs.
One of the things I love about this industry is that when you put an idea in front of trade people, they will immediately find the three things you forgot. And, frankly, some of the suggestions I received after publishing the article were too good not to add.
Tina Seale suggested KYP: KNOW YOUR PRODUCTS. This is an important one. How well do we actually understand what our companies manufacture, buy and sell? Trade Compliance needs good technical specifications and an understanding of how products fit within the HTS and ECCN structures, but we also need relationships with Engineering, Procurement and the people managing new-product introductions and engineering changes. A classification made five years ago may not remain correct if the product has evolved considerably since then. Knowing your products means understanding not only what they are called, but what they actually are.
Crister Dalen suggested KYP: KNOW YOUR PEOPLE. Since Tina already claimed KYP, I am exercising my editorial authority and modifying this one to KYH: KNOW YOUR HUMANS. 😄 This may actually be one of the most important additions. Companies are only as strong as the people running them. Do we know who has access to controlled technology and whether citizenship or status creates export-control considerations? Are our trade professionals receiving the training and resources they need? Do Sales, Engineering, Procurement, Service, Finance and senior leadership know enough about trade compliance to recognize a problem and, importantly, know whom to call when something doesn’t look right? Technology matters enormously, but compliance remains a human endeavor.
Then Imdad Ali Khan offered KYD: KNOW YOUR DELTA, and I particularly like this one because it addresses something different from my original Know Your Data. Knowing the data tells you what you have. Knowing the delta tells you what changed. A new tariff, sanction, license requirement, classification, origin determination, internal policy or government action is only useful if the change makes its way into the systems, processes and people affected by it. Trade Compliance may know Country X suddenly requires a license, but does Sales know? Does Service? Does your foreign subsidiary? Did someone update the system? Change management is compliance management.
And that brings me to my addition for this week:
KYT: KNOW YOUR TIMELINES.
We are operating in an environment where announcements, effective dates, delays, implementation guidance and actual regulatory publications do not necessarily arrive neatly together. We have recently watched proposed actions move, pause or await the Federal Register and CSMS guidance that tells industry how they will actually be implemented. Meanwhile, transshipment enforcement, new investigations, sanctions, tariffs and policy announcements continue coming at us from seemingly every direction.
Knowing what changed isn’t enough anymore. We need to know when it was announced, when it becomes legally effective, when implementation guidance arrives, what transactions are affected, whether there are in-transit provisions, and when our systems and partners need to be ready. A three-day difference can mean an enormous amount of money.
Which leads me to one final KY abbreviation that may encompass everything I’ve written over the past two weeks:
KYS: KNOW YOUR STUFF. 😂
Know your customers, suppliers, supply chains, products, humans, data, deltas, partners, transactions, enforcers, future and timelines. More importantly, build a compliance environment where all of that knowledge connects and changes can move quickly through the organization.
Because it is a new week, and, naturally, we have new regulations, new enforcement activity, new announcements and new things to figure out. That seems to be our life now.
Thank you to Tina, Crister and Imdad for proving that this framework is apparently going to require more letters than I originally anticipated. Please keep the suggestions coming. I have a feeling the KYX universe isn’t finished growing.
If you missed last week’s article and are wondering what on earth I’m talking about, you can find the original “Knowledge Is Power: It May Be Time to Redefine KYC” here:
https://vigilantgts.com/knowledge-is-power-it-may-be-time-to-redefine-kyc/
Now, enough alphabet soup. Let’s veer into this week’s Vigil and KNOW OUR STUFF.
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 # 69570464 – IMPORTANT: Review ACE Reports for Rejected Refunds Due to Lack of ACH Enrollment
U.S. Customs and Border Protection (CBP) advises Customs brokers to use the ACH Rejected Refunds Report (REV-613) report in the Automated Commercial Environment (ACE) Reports tool to help importers identify any refunds that have been rejected due to missing Automated Clearing House (ACH) enrollment.
SMS # 69570464 – IMPORTANT: Review ACE Reports for Rejected Refunds Due to Lack of ACH Enrollment
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
Administrative Orders
Export Control Regulations; Continuation of National Emergency (Notice of August 12, 2026)
| FR Document: 2026-16748 Citation: 91 FR 53179 |
PDF Page 53179 (1 page) Permalink |
| Abstract: Because the implementation of certain sanctions authorities, including sections 11A, 11B, and 11C of such Export Administration Act of 1979…is to be carried out under the International Emergency Economic Powers Act, the national emergency declared on August 17, 2001, must continue in effect beyond August 17, 2026. Therefore…continuing for 1 year the national emergency | |
Notices
Accuracy of Importer of Record Data Submitted to U.S. Customs and Border Protection
| FR Document: 2026-16911 Citation: 91 FR 53627 |
PDF Pages 53627-53628 (2 pages) Permalink |
| Abstract: This document notifies the public that U.S. Customs and Border Protection (CBP) is taking initial steps to implement Executive Order 14411 “Strengthening Customs Enforcement.” CBP is executing enhanced enforcement procedures to verify the accuracy of the information provided by new and existing importers of record on the CBP Form 5106, consistent with Executive Order 14411 and governing statutes. Importers of Record (IORs), or customs brokers providing information on the IOR’s behalf, must… | |
Antidumping or Countervailing Duty Investigations, Orders, or Reviews:
Procedures for Submissions by Importers of Automobiles Qualifying for Preferential Tariff Treatment under the United States-Mexico-Canada Agreement to Determine U.S. Content
| FR Document: 2026-16859 Citation: 91 FR 53602 |
PDF Pages 53602-53604 (3 pages) Permalink |
| Abstract: In Proclamation 10908 of March 26, 2025, “Adjusting Imports of Automobiles and Automobile Parts Into the United States,” the President imposed additional tariffs on imports of specified automobiles and automobile parts to eliminate the threat to national security posed by such imports. That Proclamation also provided that for automobiles that qualify for preferential tariff treatment under the United States-Mexico-Canada Agreement (USMCA), importers of such automobiles may submit… | |
Hearings, Meetings, Proceedings, etc.:
China’s Compliance with World Trade Organization Commitments
| FR Document: 2026-16841 Citation: 91 FR 53476 |
PDF Pages 53476-53478 (3 pages) Permalink |
| Abstract: The Office of the United States Trade Representative (USTR) is seeking public comments to assist in the preparation of its annual report to Congress on China’s compliance with its obligations as a Member of the World Trade Organization (WTO). This notice includes the schedule for the submission of comments for the China report and a public hearing. | |
News from other esteemed sources:
BAKER/MCKENZIE
White House Signals Heightened Transshipment Enforcement, Including AI-Enabled Targeting
On August 13, 2026, the Trump Administration released a report announcing its focus on illegal transshipment, where goods allegedly enter the United States through intermediary jurisdictions to reduce or avoid otherwise applicable duties, as a…
Read more…
Canada Announces Consultation on Future of Forced Labour Legislation: Import prohibition and positive due diligence obligations
On July 27, 2026, the Government of Canada launched two complementary public consultations as part of its broader effort to tackle forced labour in global supply chains. The consultations seek feedback on (1) the regulatory approach to Bill C-35, the…
Read more…
Multiple Governments Issue Joint Alert on North Korean IT Workers
08/14/2026
On July 31, 2026, authorities from the United States, Japan, the Republic of Korea, Australia, Canada, France, Germany, Italy, the Netherlands, New Zealand, and the United Kingdom issued a joint alert warning countries, companies, and other entities…
Read more…
HINRICH FOUNDATION
Does US trade policy see “scams” in every transaction?
Deborah Elms18 Aug 2026
The Trump administration now apparently sees a scam behind just about all global supply chains. Its “Great Transshipment Scam” report casts not only tariff evasion but also legitimate sourcing changes and trade involving Chinese content as illegal transshipment. The result could exacerbate the very problem Washington sought to solve.
US trade policy sees “scams” in every transaction | Article | Hinrich Foundation
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: Customs valuation can get complicated quickly when transfer-pricing adjustments, assists, royalties, intercompany charges and other costs affect the final value of imported goods. This week, we look at Customs Value Reconciliation and how strong coordination between Trade Compliance, Finance, Tax, Procurement and your customs broker can help ensure those adjustments are properly identified, documented and reported.
🎥 Watch the latest episode:
https://youtu.be/HNUgcBlwXhc?si=EHPV90a43yP5sxVm
📖 The accompanying Trade Buzz blog is available on our website:
https://vigilantgts.com/avoid-costly-import-pricing-mistakes-hb/