THE VIGILANT VIGIL – 2ND 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 second edition of the Vigilant Vigil Blog. As many of you noticed, we did not publish last week. Like many in the global trade and compliance community, we were attending the International Compliance Professionals Association (ICPA) Conference in San Antonio, Texas. It was time well spent.
ICPA once again reminded all of us why this community is so special. The conference was filled with moments that captured the spirit of the organization—powerful discussions, incredible networking, the moving choir performance, recognition of scholarship recipients, and heartfelt tributes honoring the legacy of the late Ann Lister. The sense of community and shared purpose was palpable. It is no accident that ICPA feels more like a family than an association. That culture was built intentionally by leaders like Lynda Thomas and Ann Lister, and their vision continues to shape the organization today.
San Antonio itself provided the perfect backdrop. Between the beauty of the River Walk, great food, and more than a few memorable margaritas, it was also a chance for many of us to pause and reconnect with colleagues and friends we may only see once a year. After the conference concluded, I even had a few days to relax before beginning the long drive back to Phoenix. That road trip—across desert highways and long stretches of open road—offered plenty of time to reflect on the importance of the community we have built in the trade compliance world.
Of course, while the setting was warm and welcoming, the conversations were anything but quiet. We are operating in one of the most volatile geopolitical environments in recent memory. Military actions involving Iran, the ongoing Russia–Ukraine conflict, and broader global tensions continue to reshape the landscape in which trade professionals must operate.
Yet within the trade community, the dominant topic of discussion at ICPA was clear: IEEPA refunds.
The message coming out of the conference was unmistakable—the time to act is now.
U.S. Customs and Border Protection (CBP) informed the Court of International Trade that the refund process for IEEPA tariffs is expected to be implemented in approximately 45 days, and that the process itself is not expected to be overly burdensome or documentation heavy. At face value, this sounds like good news.
However, CBP was also clear that entries will still be subject to review and enforcement actions.
So let me repeat the message we emphasized repeatedly throughout the conference: AUDIT. AUDIT. AUDIT.
Yes, you may receive your dollars back relatively “easily.” But it is almost certain that CF-28s, CF-29s, investigations, and audits will follow. Importers should be preparing now—not after refunds begin flowing.
One critical operational point that cannot be overstated: having an active ACE account and an ACH account is essential to properly prepare for and receive refunds. If your organization has not verified these capabilities, now is the time to do so.
At the same time, the broader trade enforcement landscape continues to expand. We are seeing Section 232 investigations opening across multiple industries, and the Office of the United States Trade Representative has indicated that Section 301 investigations are pending for a growing list of countries, including the European Union, Mexico, Singapore, Japan, India, and others.
Meanwhile, the legality of Section 122 tariffs is already being questioned, and many expect that we may see a similar round of litigation and court proceedings as those measures are challenged.
The complexity does not stop there. Companies seeking IEEPA refunds must also work closely with their local, state, and federal tax teams. Receiving significant tariff refunds can have real implications for previously reported profits and taxes paid. Recovering duties may expose companies to additional tax adjustments and reporting obligations.
And yet another layer of risk is emerging: consumer action groups are already mobilizing. Their argument is straightforward—if importers passed tariff costs down to consumers, and those tariffs are later refunded, consumers may seek to recover a share of those funds as well.
The administrative burden is staggering. At the same time, CBP itself continues to face systemic and staffing constraints. Many of you are still waiting for protests filed four years ago related to Section 301 exclusions, which remain unresolved and pending.
In other words, the system is under enormous strain.
So, as we move forward into what will undoubtedly be a challenging period for trade compliance professionals, we offer a few simple reminders:
Be patient with your broker.
Be proactive with your audits.
Coordinate closely with your tax teams.
And most importantly—be kind to yourself.
This is an unprecedented time in global trade compliance. None of us have navigated conditions like this before.
We hope you find the industry insights and updates that follow in this edition helpful as you work through these challenges alongside the broader trade community we are all proud to be part of.
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, 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 **
There hasn’t been a lot out of CSMS this week, mainly updates to ACE systems, like:
- Automated Transmission of Container Seal Changes to ACE Manifest Trade Information Notice. To learn more about this deployment, refer here
- CBP has updated the Appendix document in the “PGA Message Set Documents” section in CBP’s CATAIR webpag
- CSMS # 68000541 – NCSD March and April 2026 Webinars https://www.cbp.gov/trade/stakeholder-engagement/webinars
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
Lots out of the Federal Registry this week! (From policy to product) OFAC has been very active lately. Make sure your screening systems are up to date with the additions and subtractions!
Sanctions Action
| FR Document: 2026-04652 Citation: 91 FR 11595 | PDF Pages 11595-11597 (3 pages) Permalink |
| Abstract: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is publishing the names of one or more persons that have been placed on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List) based on OFAC’s determination that one or more applicable legal criteria were satisfied. All property and interests in property subject to U.S. jurisdiction of these persons are blocked, and U.S. persons are generally prohibited from engaging in transactions with them. | |
| FR Document: 2026-04681 Citation: 91 FR 11597 | PDF Page 11597 (1 page) Permalink |
| Abstract: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is publishing the name of one person and one vessel that have been removed from the Specially Designated Nationals and Blocked Persons List (SDN List). | |
Effects on the U.S. Economy of Revoking China’s Permanent Normal Trade Relations Status
| FR Document: 2026-04100 Citation: 91 FR 10130 | PDF Pages 10130-10131 (2 pages) Permalink |
| Abstract: The U.S. International Trade Commission has self-instituted Investigation No. 332-609, Effects on the U.S. Economy of Revoking China’s Permanent Normal Trade Relations Status, to produce a report as directed by the U.S. House of Representatives Committee on Appropriations analyzing revocation of permanent normal trade relations treatment for all products of China. | |
Initiation of Five-Year (Sunset) Reviews
| FR Document: 2026-04123 Citation: 91 FR 10053 | PDF Pages 10053-10055 (3 pages) Permalink |
| Abstract: In accordance with the Tariff Act of 1930, as amended (the Act), the U.S. Department of Commerce (Commerce) is automatically initiating the five-year reviews (Sunset Reviews) of the antidumping duty (AD) and countervailing duty (CVD) orders and suspended investigations listed below. The U.S. International Trade Commission (ITC) is publishing concurrently with this notice its notice of Institution of Five-Year Reviews which covers the same orders and suspended investigations. | |
Inclusions to the Section 232 National Security Adjustments to Automobile Parts Imports
| FR Document: 2026-04031 Citation: 91 FR 10066 | PDF Pages 10066-10067 (2 pages) Permalink |
| Abstract: We invite 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. | |
Certain Off-Road Vehicles and Components Thereof
| FR Document: 2026-04521 Citation: 91 FR 11336 | PDF Pages 11336-11337 (2 pages) Permalink |
| Abstract: Notice is hereby given that a complaint was filed with the U.S. International Trade Commission on February 2, 2026, under section 337 of the Tariff Act of 1930, as amended, on behalf of Polaris Inc., Polaris Industries Inc., and Polaris Sales Inc., each of Medina, Minnesota. A letter supplementing the complaint was filed on February 11, 2026. The complaint, as supplemented, alleges violations of section 337 based upon the importation into the United States, the sale for importation, and the… | |
Carbon and Certain Alloy Steel Wire Rod from Brazil, Indonesia, Mexico, Moldova, and Trinidad and Tobago
| FR Document: 2026-04121 Citation: 91 FR 10071 | PDF Pages 10071-10072 (2 pages) Permalink |
| Abstract: As a result of the determinations by the U.S. Department of Commerce (Commerce) and the U.S. International Trade Commission (ITC) that revocation of the antidumping duty (AD) orders on carbon and certain alloy steel wire rod (wire rod) from Brazil, Indonesia, Mexico, Moldova, and Trinidad and Tobago and revocation of the countervailing duty (CVD) order on wire rod from Brazil would likely lead to the continuation or recurrence of dumping, countervailable subsidies, and material injury to an… | |
Certain Laptops, Routers and Gateways, and Components Thereof
| FR Document: 2026-04494 Citation: 91 FR 11086 | PDF Pages 11086-11087 (2 pages) Permalink |
| Abstract: Notice is hereby given that a complaint was filed with the U.S. International Trade Commission on February 2, 2026, under section 337 of the Tariff Act of 1930, as amended, on behalf of AX Wireless, LLC of Austin, Texas. Supplements to the complaint were filed on February 10, 2026. The complaint, as supplemented, alleges violations of section 337 based upon the importation into the United States, the sale for importation, and the sale within the United States after importation of certain… | |
News from other esteemed sources:
BAKER/MCKENZIE
Webinar summary: US Supreme Court ruling triggers major shifts in US trade enforcement strategy
To kick off its 2026 Global Trade and Customs Webinar Series Baker McKenzie’s global customs team led a discussion on the impact of the US Supreme Court’s recent IEEPA ruling and how the decision reshapes the global trade landscape. Below are the… Read more…
SANDLER, TRAVIS & ROSENBERG LAW
Tariffs Today: How Section 122 Tariffs are Being Challenged
At least two separate cases have now been filed at the Court of International Trade seeking to stop the Trump administration from utilizing Section 122 of the 1974 Trade Act to impose tariffs on all imports into the U.S. https://www.strtrade.com/trade-news-resources/str-trade-report/trade-report/march/tariffs-today-how-section-122-tariffs-are-being-challenged?mkt_tok=NzIzLVdPWi00NDYAAAGgeE8uBwvhH0VwlXAM9cGDtLAkii_MkhV4T-uTUrrKOZfmHzx6Hbc03SJGhgpcVGBpeDCRjbZ0ApYUBw3DlUiM-lOswLBBqgYUJTHo50j3MuSz
KPMG
Kelly Nelson posted some truly relevant information about the new USTR announced 301 investigations on Linked In. The link to Kelly’s post is below and the link to the USTR Press Release. https://www.linkedin.com/posts/kellynelsonkpmg_ustr-301-frn-industrial-excess-capacity-3-share-7437649783739297792-cQD1?utm_source=share&utm_medium=member_desktop&rcm=ACoAAACx2GMBB_IkmfckiajaF8zRrDb629jVAMM
CSIS-The Trade Guys
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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, April 28 – 29 Dallas, TX
Jamie Adams will be attending sessions and happy to connect with you.
ICPA Canada Conference, June 7 – 10 Toronto, Ontario Canada
Jamie Adams will be presenting, again, on the importance of US and CA Customs Entry and Broker Audits. The choir will also be singing, and we are looking to increase in number. You do receive a 33% discount for singing with us.
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.
To join ICPA or our conferences, please visit: www.icpainc.org
TRADE BUZZ – Powered by Vigilant GTS
Joe Burks has moved on to a new position at a new company, and he has graciously handed the reigns of Trade Buzz to Jamie Adams.
We posted a video this week explaining the new direction of Trade Buzz. https://youtu.be/0J6JBuCIu5M?si=axA2t05V0NAIxEDi
Check back with us every Tuesday as we will be publishing new quick topic videos every week. Please also watch for the Newsletter announcements of our 30-to-45-minute Trade Buzz Webinars to be scheduled soon.
You can see the library of all our videos on our website at: https://vigilantgts.com/webinars/