THE VIGILANT VIGIL – 37th 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.

 

Vigil Viewpoint:

THE ART OF NOT DOING IT ALL

Mexico City, Missing Out, and the Compliance Professional’s Never-Ending To-Do List

Last week, I was supposed to be in Mexico City.

Not just visiting Mexico City, mind you. I was scheduled to speak at the ICPA Mexico Conference, which combines several of my favorite things in life: international trade compliance, travel, interesting people, a microphone, and an audience that actually WANTS to hear someone talk about customs regulations. (I realize that last one is a rather specialized demographic.)

And then there’s Mexico City itself. The architecture! The art! The history! THE FOOD! I had been looking forward to returning and spending a little more time exploring a city that deserved considerably more attention than my previous fly-in, meet, and fly-out experience had allowed.

Best of all, I would have been traveling and spending time with some of my favorite people: Elisabeth, Victoria, Lynda, and the wonderful collection of colleagues and friends I affectionately consider my ICPA family. There’s something special about the conversations between conference sessions, the laughter over dinner, and the friendships that develop when people who share an unusual enthusiasm for tariff classifications get together.

So when the photographs and social media posts started appearing last week, I experienced a rather substantial case of FOMO.

For those unfamiliar with the expression, that’s Fear of Missing Out. And let me assure you, seeing your friends enjoying Mexico City while you’re sitting at your desk staring at another overflowing inbox is a particularly effective way to experience it.

But here’s the thing. I had made the right decision not to go.

And I still hated missing it.

Sometimes the Right Decision Isn’t the Fun One

September and early October involved a considerable amount of travel, including international trips, conferences, presentations, and the usual assortment of professional commitments. I love those opportunities, but eventually the travel, the workload, and the demands on my personal health began catching up with me.

Meanwhile, several important projects were demanding more attention than I had been able to give them. Another week away would have been wonderful for my enthusiasm and considerably less wonderful for my growing list of responsibilities.

So I did something I don’t particularly enjoy doing.

I said NO to something I genuinely wanted to do.

Not because the conference wasn’t valuable. Not because the people weren’t important. And certainly not because I had suddenly lost my enthusiasm for Mexican food. I simply recognized that there were other things requiring my attention, and that continuing to say YES to every worthwhile opportunity was becoming unsustainable.

Sometimes we have to sacrifice something good to make room for something necessary. And sometimes the most responsible decision is the one that leaves us feeling a little disappointed.

Which brings me, naturally, to global trade compliance.

The Never-Ending Compliance To-Do List

If you work in international trade, you probably have a to-do list that could qualify as a controlled document simply because of its size.

There are classifications to validate, restricted party screening results to adjudicate, origin determinations to review, free trade agreement qualifications to complete, and customs valuations to examine. There are shipments sitting on hold, brokers waiting for instructions, suppliers who haven’t returned questionnaires, and customers who would very much appreciate receiving their merchandise sometime before the next fiscal year.

Then come the bigger projects. Updating policies and procedures. Implementing a UFLPA due diligence program. Reviewing entry data. Conducting internal audits. Preparing for broker and forwarder quarterly business reviews. Completing training and maintaining professional qualifications. And, because it’s November, there are year-end budgets, performance appraisals, and planning exercises waiting patiently in the background.

Actually, they’re not waiting patiently. They’re sending reminders.

And just when you think you might be getting ahead, along comes another Federal Register notice, CBP Cargo Systems Messaging Service update, HTS revision, restricted party list addition, or regulatory development that requires someone to drop everything and figure out what it means.

Add the continuing administrative challenges surrounding tariff refunds and other duty recovery opportunities, and it’s enough to make even the most organized compliance professional contemplate a career in something less complicated.

Perhaps juggling chainsaws.

At least with chainsaws, you can generally see what’s coming.

Urgent Doesn’t Always Mean Important

Here’s where I think many compliance programs struggle. We’re so busy responding to the next urgent request that we don’t always stop to consider whether it’s the most important use of our time.

A shipment is stuck, so everyone drops everything to get it released. That’s understandable, particularly when a production line is waiting for critical components. But what if that same shipment has been held three times because nobody has corrected the underlying product master data?

We can spend hours resolving the immediate problem, or we can invest some time in fixing the process that keeps creating it.

Likewise, we can manually review hundreds of routine, low-risk transactions, or we can establish appropriate controls that allow us to focus our expertise on the transactions that actually warrant closer scrutiny.

And we can spend every available hour responding to regulatory developments, or we can establish a disciplined process for determining which changes require immediate action, which require planning, and which simply need to be monitored.

The objective isn’t to do less compliance. It’s to spend our limited time and resources doing the compliance work that matters most.

That requires understanding the difference between what is legally mandatory, what is genuinely high-risk, what is operationally urgent, and what is simply something we’d LIKE to accomplish.

Those categories aren’t always the same.

Sometimes You Have to Put Your Foot Down

I’ve been thinking about an analogy from cycling. When you’re stopped at an intersection with your feet secured in toe clips, you can sometimes maintain your balance for a few moments by making tiny adjustments to the handlebars and shifting your weight.

But eventually, if you can’t move forward, you have to release a foot and put it on the ground.

Otherwise, gravity makes the decision for you.

I think many of us approach our professional responsibilities in much the same way. We keep making little adjustments, shifting deadlines, working longer hours, and convincing ourselves that we can somehow maintain the entire operation without ever stopping.

And sometimes we can.

But sometimes we need to recognize that the better decision is to put a foot down, reassess our priorities, and give ourselves a stable foundation before moving forward again.

For me, that meant missing Mexico City.

For a compliance team, it might mean postponing a desirable system enhancement to address a critical screening weakness, assigning routine documentation reviews to trained personnel so specialists can focus on complex classifications, or delaying a lower-priority initiative to correct recurring entry errors before they become a regulatory problem.

It might also mean admitting that the department simply doesn’t have the resources to accomplish everything being requested and having an honest conversation with leadership about what needs to change.

Prioritization isn’t an admission of failure. It’s an essential part of responsible management.

And Yes, Sometimes You Have to Eat the Broccoli

Anyone who knows me well knows that I have a deep appreciation for meat, cheese, bread, potatoes, fruit, and practically anything containing sugar.

Vegetables? Not so much.

I’m not particularly fond of their flavor, and I have even less enthusiasm for some of their textures. Given the choice between a warm dinner roll and a serving of broccoli, I can assure you the broccoli is going to have a difficult time competing.

But sometimes the choice isn’t about what we enjoy most. It’s about what we need.

Compliance programs face the same dilemma. Conference attendance, new technology, interesting research projects, and strategic initiatives can be exciting and professionally rewarding. Updating a procedure, reviewing an aging audit finding, cleaning up master data, or documenting an uncomfortable internal control weakness may be considerably less appealing.

Nevertheless, those less glamorous activities are often what keep the program healthy.

And occasionally, we have to put down the roll and eat the broccoli.

Preferably with cheese. I’m not completely unreasonable.

Making Room for What Matters

As we approach the end of the year, I’d encourage compliance professionals and business leaders to take a serious look at their priorities. Not simply at everything they’d like to accomplish, but at what the organization truly needs from them.

Which activities are mandatory? Which risks could create the greatest consequences if ignored? Which recurring problems deserve a permanent solution rather than another temporary workaround? What can be automated, delegated, simplified, or eliminated without weakening compliance?

And perhaps most importantly, what are we continuing to do simply because we’ve always done it that way?

Technology, including the intelligent automation we’ve been discussing in recent Trade Buzz episodes, can help us answer some of those questions. But even the best technology can’t make every competing priority equally important. Leadership, professional judgment, and an honest assessment of available resources still matter.

I don’t regret my decision to stay home last week, although I certainly regret missing the experience. There’s a difference. I would have loved the conference, the people, the conversations, the art, and, yes, every delicious opportunity to avoid broccoli in Mexico City.

But I needed to take care of some things closer to home, both personally and professionally.

And sometimes that’s enough.

We don’t have to attend every conference, launch every initiative, answer every email immediately, or personally resolve every problem that crosses our desks. We do, however, need to understand our responsibilities, recognize our limitations, and make thoughtful decisions about where our attention will have the greatest impact.

Because doing everything isn’t the same as doing what matters.

Now, if you’ll excuse me, I have a few more things to cross off my list. And somewhere in Mexico City, I suspect my ICPA family is still recovering from a wonderful week of presentations, networking, and exceptional food.

I missed you all. Next time, I hope to be there.

And I promise to give the broccoli some consideration.

Let’s veer into this week’s Vigil, shall we?

 

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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

**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.**

 

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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 # 70381183 – Updates to CBP Form 3461 and CBP Form 7501, and their Electronic Equivalents, Pursuant to the Interim Final Rule on Heightened Requirements for Foreign Importers of Record

Pursuant to Executive Order 14411, “Strengthening Customs Enforcement”, Section 2, and governing statutes, U.S. Customs and Border Protection (CBP) is establishing new requirements for foreign importers of record (IORs) when making entry, and corresponding responsibilities for licensed customs brokers.  See Interim Final Rule (IFR), “Heightened Requirements for Foreign Importers of Record”, 91 FR 69977, dated November 6th, 2026

CSMS # 70381183 – Updates to CBP Form 3461 and CBP Form 7501, and their Electronic Equivalents, Pursuant to the Interim Final Rule on Heightened Requirements for Foreign Importers of Record

 

 

CSMS # 70409426 – Foreign Importer of Record: Updated CATAIRs and Error Dictionaries

U.S. Customs and Border Protection (CBP) will deploy the Foreign Importer of Record (IOR) Enhancement to the ACE Certification (CERT) environment on November 12, 2026, followed by deployment to the Production (PROD) environment on January 5, 2027. In support of this deployment, CBP has published the following

CSMS # 70409426 – Foreign Importer of Record: Updated CATAIRs and Error Dictionaries

 

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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

 

Rules

Heightened Requirements for Foreign Importers of Record

FR Document: 2026-22735 Citation: 91 FR 69977

PDF Pages 69977-70007 (31 pages) Permalink

Abstract: This document amends the U.S. Customs and Border Protection (CBP) regulations, consistent with Section 2 of Executive Order 14411, “Strengthening Customs Enforcement,” by establishing new requirements for foreign importers of record (IORs) when making entry, and corresponding responsibilities for licensed customs brokers with regard to their clients. The new regulations also set forth consequences for foreign IORs and customs brokers who fail to comply with the new requirements.

 

Extension of the Suspension of Expansion of End-User Controls for Affiliates of Certain Listed Entities

FR Document: 2026-22793 Citation: 91 FR 70789	PDF Pages 70789-70790 (2 pages) Permalink
Abstract: The Bureau of Industry and Security (BIS) is extending the suspension of the interim final rule (IFR), “Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities.” The suspension was set to end November 9, 2026. This final rule extends the suspension through January 10, 2027.

 

 

Notices

Determination:

Vietnam’s Acts, Policies, and Practices Related to Intellectual Property Protection and Enforcement; Extension of Section 301 Investigation

FR Document: 2026-22868 Citation: 91 FR 72609	PDF Pages 72609-72610 (2 pages) Permalink
Abstract: The United States Trade Representative (Trade Representative) has determined to extend for three months the ongoing Section 301 investigation of certain acts, policies, and practices of the Government of Vietnam related to intellectual property (IP) protection and enforcement.

 

 

Product Exclusion Extensions:

China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation

FR Document: 2026-22925 Citation: 91 FR 72610

PDF Pages 72610-72611 (2 pages) Permalink

Abstract: In prior notices, the U.S. Trade Representative (Trade Representative) modified the actions in the Section 301 investigation of China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation by excluding from additional duties certain products of China. While most exclusions have expired in prior years, certain exclusions remain in force. This notice announces the Trade Representative’s determination to further extend all 178 current exclusions.

 

Sanctions Actions (1 of 7)

FR Document: 2026-23009 Citation: 91 FR 72957

PDF Pages 72957-72958 (2 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.

 

 

Antidumping or Countervailing Duty Investigations, Orders, or Reviews:

Steel Wire Garment Hangers from the People’s Republic of China and the Socialist Republic of Vietnam

FR Document: 2026-22658 Citation: 91 FR 70055

PDF Pages 70055-70060 (6 pages) Permalink

Abstract: The U.S. Department of Commerce (Commerce) determines that imports of steel wire garment hangers (hangers), completed in Cambodia using: (1) steel wire or (2) steel wire and paper accessories, produced in the People’s Republic of China (China) or the Socialist Republic of Vietnam (Vietnam), are circumventing the antidumping duty (AD) order on hangers from China, or the AD and countervailing duty (CVD) orders on hangers from Vietnam.

 

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News from other esteemed sources:

 

THOMPSON/HINE

BIS Extends “Affiliates Rule” Until January 2027

By Scott E. Diamond** & Francesca M.S. Guerrero on November 6, 2026

On November 5, 2026, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that it is extending the suspension of its End-User Controls to Cover Affiliates of Certain Listed Entities rule. The suspension was set to expire on November 9, 2026, but will now be extended through January 10, 2027.

BIS Extends “Affiliates Rule” Until January 2027 | SmarTrade

 

 

ST&R

CBP Imposes Heightened Requirements for IORs and Customs Brokers

November 5, 2026 // Trade Report

U.S. Customs and Border Protection has issued an interim final rule that will establish new requirements for foreign importers of record when making entry, corresponding responsibilities for licensed customs brokers with regard to their clients, and consequences for foreign IORs and brokers that fail to comply with the new requirements.

CBP Imposes Heightened Requirements for IORs and Customs Brokers | Sandler, Travis & Rosenberg, P.A.

 

 

BAKER/MCKENZIE

BIS Extends Suspension of the “Affiliates Rule” Through January 10, 2027
11/05/2026
After much anticipation, on November 5, 2026, the US Department of Commerce’s Bureau of Industry and Security (“BIS“) released a final rule formally extending the suspension of the “Affiliates Rule” through January 10,…
Read more…

 

UK: UK Government Confirms Plans to Introduce Mandatory Human Rights Due Diligence Regime

On 4 November 2026, the UK Government confirmed plans to introduce a mandatory human rights due diligence regime for large businesses. The regime will apply to UK businesses with global turnover above £350 million and non-UK businesses generating…
Read more…

 

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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:

 

ICPA Annual Spring Conference, March 7 – March 10, 2027

Orlando, Florida, USA

This will be the 25^th Anniversary Event for ICPA.

Jamie Adams will be presenting on “Networking for Career Development” and leading the Voices of Compliance Choir in multiple performances.

 

ICPA Global Trade Insights Conference, April 7 – April 8, 2027

Wembley, England

Jamie Adams will be presenting and also leading the choir.

 

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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: Global trade recordkeeping is about more than saving commercial invoices and shipping documents. Effective compliance requires maintaining accurate, organized, and accessible records that support classification, valuation, country of origin, screening, and other regulatory decisions. Strong recordkeeping practices include understanding retention requirements, documenting the rationale behind compliance decisions, and ensuring supporting evidence can be retrieved when needed. It’s about building an audit-ready compliance program that reduces risk, demonstrates reasonable care, and makes preparing for a CBP audit considerably less stressful.

🎥 Watch the latest episode:

https://vigilantgts.com/organize-records-confidently-pass-audits-hb/

 

Missed a previous episode? Browse the complete Trade Buzz library at:
https://vigilantgts.com/blog/