THE VIGILANT VIGIL – 4TH EDITION

March 26, 2026

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 fourth edition of the Vigilant Vigil.

This week, I’m going to ask you to do something a little different.

GIRD YOUR LOINS!

Now—before anyone takes that the wrong way—let’s go back to its roots. Historically, people wore long robes or tunics. Practical for daily life, yes—but not exactly ideal for travel, work, or battle. So before setting out, they would gather up those robes, pull them tight, and secure them with a belt or sash. It freed their movement. It reduced the risk of tripping. It was the first act of preparation.

Only after that did they put on their armor—protecting what mattered most before stepping into uncertainty.

Because here’s the truth: you could carry every weapon available—but if you were not protected, you were vulnerable.

That analogy hits very close to home in global trade today.

Many organizations are still operating with “robes down”—manual processes, fragmented data, outdated assumptions, and a reliance on how things used to work. And for a long time, that was enough. The system was more predictable. Enforcement was more measured. There was room to react.

That is no longer the environment we are in.

We are seeing a clear shift—not just in trade policy, but in overall government posture. The language, the actions, the priorities—they are different. The rebranding toward a more war-focused defense posture, increased military activity abroad, and a willingness to project power more aggressively all point to a broader mindset shift.

We’ve seen direct military actions, including operations in Venezuela and escalating conflict with Iran.

We’ve seen serious discussions around acquiring strategic territories like Greenland in the name of national security.

This is not the same global posture we were operating under just a few years ago.

And whether we like it or not—that mindset flows downstream.

It flows into enforcement.

It flows into expectations.

And it absolutely flows into trade compliance.

CBP, BIS, OFAC—these agencies are not operating in a vacuum. They are part of a broader system that is becoming more assertive, more data-driven, and less tolerant of gaps.

And yet—many companies are still sitting behind their walls thinking:

“We’ve never been audited.”

“We’ve never had an issue.”

“We’re probably fine.”

If you’ve ever watched The Lord of the Rings, you know how that story goes. The fortress that had never fallen… fell. Not because the walls weren’t strong—but because no one expected how the breach would come.

That is where we are today.

You can submit filings. You can request refunds. You can send your “arrows over the wall.” But do not assume there won’t be a response. Because there will be—and it may come back faster, stronger, and more aggressively than you expect.

CF28s.

CF29s.

Audits.

Investigations.

Penalties.

So, before anything else—before strategy, before tools—you need to gird your loins.

Secure your foundation.

That means:

Getting visibility into your data (ACE is not optional—it is essential)
Establishing financial readiness (ACH is a requirement)
Auditing your entries—now, not later
Building and documenting defensible policies and procedures
Surrounding yourself with the right partners—brokers, legal counsel, consultants, and technology providers

Because you can have all the “weapons” in the world—but if you are not protected, you are exposed.

And let me be very clear: this is just the beginning.

IEEPA was not the end of the story—it was the opening chapter. Section 122, 232, 301, UFLPA enforcement, sanctions, export controls—this is a system that is expanding in both scope and intensity.

Trade compliance is no longer a back-office function.

It is strategic.

It is operational.

It is financial.

And increasingly—it is existential.

So, take the time—yes, even when you feel like you don’t have it.

Assess. Prepare. Strengthen.

Gird your loins. Put on your armor. Get ready.

Because hoping the wall holds is not a strategy.

Preparation is.

And as always, if you need support—whether across people, process, or technology—we’re here. And if we’re not the right fit, we’ll help you find the partners who are.

Let’s stay vigilant—and ready for what’s next.

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
CBP news
Cooperative call outs to other blogs and Industry professionals
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 # 68096516 – Implementation of Jones Act Waiver Issued to the Department of War, Dated March 17, 2026

On March 17, 2026, the Department of Homeland Security (DHS) issued a limited waiver of 46 U.S. C. § 55102 (the “Jones Act”) pursuant to 46 U.S.C. § 501(a), at the request of the Department of War. The approved waiver covers a 60-day period that expires at 11:59 p.m. Eastern Daylight Time on Sunday, May 17, 2026. U.S. Customs and Border Protection (CBP) requests that any member of the trade community who intends to conduct transportation of commodities listed in the attachment on a foreign-flag vessel…

https://content.govdelivery.com/accounts/USDHSCBP/bulletins/40f1204

CSMS # 68087488 – New ACE Drawback Error Validations Deployed to ACE CERT Environment March 17, 2026

Two new Drawback error messages deployed to the Automated Commercial Environment (ACE) Certification (CERT) environment on Tuesday, March 17, 2026…

With this change, new ACE validations allow claimants to file drawback claims for the specific eligible Section 232 tariffs (Auto parts and Truck parts) for provisions 1313(a) and 1313(b)…

CSMS # 68087488 – New ACE Drawback Error Validations Deployed to ACE CERT Environment March 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

Request for Membership Application: Defense Trade Advisory Group

FR Document: 2026-05408 Citation: 91 FR 13393	PDF Pages 13393-13394 (2 pages) Permalink
Abstract: The U.S. Department of State’s Bureau of Political-Military Affairs (the Bureau) is accepting membership applications for the Defense Trade Advisory Group (DTAG). The Bureau is interested in applications from subject matter experts, including from the United States defense industry, relevant trade and labor associations, and academic and foundation personnel.

Industry Trade Advisory Committees, Request for Membership Application; Correction

FR Document: 2026-05409 Citation: 91 FR 13394	PDF Page 13394 (1 page) Permalink
Abstract: The Secretary of Commerce and the United States Trade Representative (Trade Representative) published a document in the Federal Register of March 12, 2026, concerning application for qualified individuals interested in serving as member of the Industry Trade Advisory Committees (ITACs). The document contained a broken weblink.

Opening of the Inclusions Window for the Section 232 Automobile Parts Tariff Inclusions Process

FR Document: 2026-05681 Citation: 91 FR 13998	PDF Page 13998 (1 page) Permalink
Abstract: The Bureau of Industry and Security (BIS), working with the International Trade Administration (ITA) has established a process for including additional automobile parts within the scope of the duties authorized by the President under section 232 of the Trade Expansion Act of 1962. This notice opens the April 2026 inclusions window for submissions.

Antidumping or Countervailing Duty Investigations, Orders, or Reviews:

Certain Steel Wheels from the People’s Republic of China

FR Document: 2026-05443 Citation: 91 FR 13280	PDF Pages 13280-13282 (3 pages) Permalink
Abstract: In response to a request from Accuride Corporation (Accuride) and Maxion Wheels USA LLC (Maxion) (domestic interested parties), the U.S. Department of Commerce (Commerce) is initiating a country-wide circumvention inquiry to determine whether imports of certain steel wheels from the Socialist Republic of Vietnam (Vietnam) are circumventing the antidumping duty (AD) and countervailing duties (CVD) orders on certain steel wheels from the People’s Republic of China (China).
FR Document: 2026-05445 Citation: 91 FR 13291	PDF Pages 13291-13293 (3 pages) Permalink
Abstract: In response to a request from Accuride Corporation (Accuride) and Maxion Wheels USA LLC (Maxion) (domestic interested parties), the U.S. Department of Commerce (Commerce) is initiating a country-wide circumvention inquiry to determine whether imports of certain steel wheels from Thailand are circumventing the antidumping duty (AD) and countervailing duties (CVD) orders on certain steel wheels from the People’s Republic of China (China).

Investigations; Determinations, Modifications, and Rulings, etc.:

Oil Country Tubular Goods from India, South Korea, Turkey, Ukraine, and Vietnam

FR Document: 2026-05675
Citation: 91 FR 14039

PDF Pages 14039-14040 (2 pages)
Permalink

Abstract: The Commission hereby gives notice of the scheduling of full reviews pursuant to the Tariff Act of 1930 to determine whether revocation of the countervailing duty orders on oil country tubular goods from India and Turkey and the antidumping duty orders on oil country tubular goods from India, South Korea, Turkey, Ukraine, and Vietnam would be likely to lead to continuation or recurrence of material injury within a reasonably foreseeable time. The Commission has determined to exercise its..

Sanctions Action: (10 individuals, 6 Entities)

FR Document: 2026-05748
Citation: 91 FR 14624

PDF Pages 14624-14629 (6 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.

CBP News

**The following are short summaries of the actual information provided by CBP. To find more stories and stay up to date, you can find more at: Media Releases | U.S. Customs and Border Protection

CBP Launching New Payment Collection System

03/25/2026 12:45 PM EDT

THOMAS, Virgin Islands — U.S. Customs and Border Protection announced today a major advancement in trade modernization for the U.S. Virgin Islands: the use of Pay.gov for all payments of duties, taxes, and fees on imported merchandise.In…

CBP Launches Pay.gov for U.S. Virgin Islands Imports

News from other esteemed sources:

THOMPSON/HINE

Government Increases Compliance Obligations for Contractors Providing or Using AI and AI Companies

Recent federal government actions regarding contractor offering and use of artificial intelligence (AI) products raise significant issues for government contractors and AI companies.

View the entire bulletin in PDF format.

SANDLER/TRAVIS/ROSENBURG

March 24, 2026 // Trade Report

CIT Order Affirms Importance of Filing Protests for IEEPA Tariff Refunds

An order issued March 20 by a Court of International Trade judge affirms that…importers should continue filing timely protests of liquidated entries to protect their right to potential refunds of IEEPA tariffs.

CIT Order Affirms Importance of Filing Protests for IEEPA Tariff Refunds | Sandler, Travis & Rosenberg, P.A.

March 25, 2026 // Trade Report

Tariffs Today: Section 232 Tariff Could be Expanded to More Auto Parts

The International Trade Administration has announced that it will accept requests to add more imported automobile parts to the scope of the Section 232 tariff on such goods from April 1 through April 14.

Tariffs Today: Section 232 Tariff Could be Expanded to More Auto Parts | Sandler, Travis & Rosenberg, P.A.

BAKER/MCKENZIE

2026 Canadian Trade & Customs Outlook: Customs

As 2026 brings new compliance challenges and opportunities, Baker McKenzie’s Canadian international trade team is here to help you stay ahead. We are launching our annual series of insights that unpack 2025’s biggest developments and spotlight the…

THE VIGILANT VIGIL – 4TH EDITION

Investigations; Determinations, Modifications, and Rulings, etc.:

Oil Country Tubular Goods from India, South Korea, Turkey, Ukraine, and Vietnam

Sanctions Action: (10 individuals, 6 Entities)

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