THE VIGILANT VIGIL – 28th 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.
Foreword: CBP Trade and Cargo Security Summit Recap
I spent the better part of this week at the CBP Trade and Cargo Security Summit in Dallas, and after several days of listening to government officials, industry leaders, attorneys, brokers, technology providers and fellow trade professionals talk about where customs and trade enforcement are headed, I came away with a fairly clear conclusion: the expectations being placed on the trade community are increasing, and they are moving further upstream into the supply chain. That probably will not surprise regular readers of the Vigil, but the consistency with which that message appeared throughout the Summit certainly deserves our attention.
We have put together a much longer recap entitled “The Soundtrack of TCSS 2026: We’re All in This Together… Aren’t We? Reflections and Key Takeaways from the 2026 CBP Trade and Cargo Security Summit,” which will be linked at the end of this foreword. Because apparently I am incapable of attending a trade conference without somehow turning it into a musical production, I gave the Summit a nine-song soundtrack. Links to the songs and their YouTube videos are included in the full article. For those of you who do not have the time, patience or questionable musical curiosity required to read the entire thing, however, I wanted to capture the most important messages here.
The title song, “We’re All in This Together” from High School Musical, actually captures one of the strongest themes I heard in Dallas. CBP, importers, exporters, brokers, carriers, technology providers and other participants in the trade community are operating in an increasingly interconnected environment. Government and industry will not always agree, but the Summit repeatedly reinforced the need for cooperation, communication and better information throughout the supply chain. Of course, I added the “…Aren’t We?” because this is international trade, and I am apparently incapable of leaving well enough alone.
If there was a recurring chorus throughout the Summit, it was visibility. CBP increasingly wants to understand not merely what crossed the border, but who made it, who supplied it, where its components and materials came from, how it moved, who touched the transaction, what documentation supports the declarations, and whether the importer can demonstrate that it exercised Reasonable Care before the goods ever arrived. That message fits almost perfectly with the Heightened Import Disclosures for Supply Chain Visibility ANPRM we discussed in last week’s Vigil. The direction of travel is becoming difficult to miss: Customs compliance is moving upstream.
That also means data matters more than ever. Classification, valuation, country of origin, tariff applicability, supplier information, admissibility, forced labor, sanctions, ownership and documentation cannot live comfortably in separate organizational silos anymore. CBP is increasingly capable of comparing information across systems, transactions, parties and agencies. If your commercial invoice says one thing, your broker transmits another, your supplier documentation says something else and your internal system contains a fourth version of the truth, eventually someone or something is going to notice. Which brings us rather appropriately to another song on my Summit soundtrack: “Somebody’s Watching Me.”
Technology and artificial intelligence were therefore another unmistakable part of the conversation. CBP is using more sophisticated data analysis and automation, and the private sector is doing the same. I continue to believe AI can be extraordinarily valuable in trade compliance, but the message from the Summit reinforced something we have said repeatedly in the Vigil: technology does not eliminate Reasonable Care. It makes good data more powerful and bad data more dangerous. Automation can identify patterns, compare documents, screen parties and expose anomalies at a scale that humans simply cannot achieve, but somebody still needs to understand what the technology is doing, validate the results and make defensible compliance decisions. Trust, but verify. Or, increasingly, verify and then trust.
C-TPAT was another particularly important theme, and I came away from the Summit believing we need to think differently about the word voluntary. C-TPAT remains a voluntary program. Nothing announced at the Summit changed that. At the same time, participation is increasingly connected to benefits, trusted-trader concepts, supply-chain visibility and access to other programs and opportunities. There is an important distinction between something being legally mandatory and becoming practically important to doing business in a changing enforcement environment. Companies that have historically dismissed C-TPAT because “we don’t have to do it” may want to reconsider that analysis.
The broader enforcement message was equally clear. Tariffs remain complicated. Supply chains remain complicated. Forced labor, sanctions, transshipment, valuation, classification, origin and documentation are receiving greater scrutiny. CBP understands that mistakes happen, but the days when a company could reasonably treat Customs compliance as something handled exclusively by the broker at the border are disappearing quickly. The broker files the entry. The importer owns the compliance program. Procurement, sourcing, logistics, finance, legal, IT and foreign operations increasingly have a role in getting that entry right.
That is where another song on my soundtrack, Queen and David Bowie’s “Under Pressure,” begins to feel particularly appropriate. Trade compliance professionals are being asked to manage rapidly changing tariffs, expanding enforcement priorities, increasingly complex supply chains, new technologies and greater expectations for data, documentation and visibility, often all at the same time. The answer cannot simply be to work faster. Companies need better processes, better information, better technology and better cooperation across their organizations.
Perhaps that was the most important message I heard beneath all the individual presentations. Trade compliance is no longer simply a Customs function. It is operational, financial, technological, legal and strategic. A strong program requires accurate data, documented decisions, supplier cooperation, meaningful internal controls, ongoing audits and people who understand how all of those pieces connect. A beautiful compliance manual sitting untouched on a shelf is not a compliance program. Neither is a sophisticated GTM system filled with inaccurate information. The controls have to work in the real world.
There was also an encouraging side to the Summit. For all the complexity, uncertainty and occasional frustration surrounding trade today, there was an extraordinary amount of collaboration in Dallas. Government and industry may not always agree on how a particular rule should work, but there was real dialogue about implementation, technology, enforcement, security and the practical realities facing importers and exporters. That matters. Trade works best when government understands how businesses actually operate and when businesses understand what government is trying to accomplish. Maybe, just maybe, we really are all in this together.
So what should you take away from Dallas? Know your supply chain. Know your data. Know your suppliers. Document your decisions. Audit your transactions. Pay attention to C-TPAT. Use technology intelligently. And do not wait for a CF-28, CF-29, audit or enforcement action to discover what you do not know. The government is telling us, with increasing clarity, where enforcement and compliance expectations are headed. We should probably listen.
The full article linked below goes much deeper into the individual sessions, the people, the observations and the complete soundtrack. Along the way we manage to work in The King and I, The Sound of Music, The Parent Trap, The Clash, Bonnie Tyler and even “I’m in the Army Now.” I promise there is actually a trade-compliance reason for every one of them. Mostly.
But if you never make it past this foreword, remember the chorus: visibility, data, verification, collaboration and Reasonable Care. Those themes showed up again and again in Dallas, and I suspect we will be hearing them for a very long time.
For those willing to hear the entire album, the full “Soundtrack of TCSS 2026: We’re All in This Together… Aren’t We?” will be linked below, including links to all nine songs and their corresponding YouTube videos.
https://vigilantgts.com/the-soundtrack-of-tcss-2026-were-all-in-this-together-arent-we/
Let’s veer into this week’s Vigil, shall we?
In this volume, we will explore:
- Updates to the Federal Registry, for both policy and product
- CSMS updates
- 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.**
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
Implementation of Section 338(g)
| FR Document: 2026-18385 Citation: 91 FR 57387 |
PDF Pages 57387-57389 (3 pages) Permalink |
| Abstract: Pursuant to section 338(g) of the Tariff Act of 1930, the United States International Trade Commission (Commission) has a duty to ascertain and at all times to be informed of discriminations against the commerce of the United States pursuant to section 338(a), (b), and (e) and to provide the President with this information as well as recommendations. In furtherance of this duty, and as described in further detail below, the Commission invites comments from interested persons regarding how the… | |
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 # 69827440 – Document Image System (DIS) Validation of Internal Transaction Number (ITN) for Electronic Export Information (EEI) Submissions (CBP-255) Deployed to ACE in the Certification Environment and Updated DIS Implementation Guide is Now Available
U.S. Customs and Border Protection (CBP) has deployed the following enhancement to the Automated Commercial Environment (ACE) Certification Environment: Document Imaging System (DIS) Validation of Internal Transition Number (ITN) for Electronic Export Information (EEI) Submissions (CBP-255). This enhancement will be deployed in the ACE Production environment on October 8, 2026.
News from other esteemed sources:
BAKER/MCKENZIE
Canada Releases Details of New Retaliatory Tariffs Against U.S. Goods
On September 8, 2026, the Government of Canada released the United States Surtax Order, 2026 (the 2026 Order), implementing Canada’s latest round of retaliatory tariffs on imports from the United States. The Canada Border Services Agency (CBSA)…
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:
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: The future of USMCA may still be in question, but your obligation to exercise Reasonable Care remains firmly intact. If you are claiming USMCA benefits today, make sure your qualification, supplier documentation, rules of origin analysis and audit trail can support those claims tomorrow.
🎥 Watch the latest episode:
https://www.youtube.com/watch?v=1Seuhu0xSSo
Missed a previous episode? Browse the complete Trade Buzz library at:
https://vigilantgts.com/webinars/