THE VIGILANT VIGIL – 5TH 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 fifth edition of the Vigilant Vigil.
This week’s message is a little more personal.
Over the weekend, I had a significant health scare. For several days, I was dealing with shortness of breath, elevated heart rate, headaches, sweating, chest pressure, and extreme fatigue. As an asthmatic living in Phoenix—where the pollen and pollution were especially bad—I assumed that was the cause. I even saw my doctor, who agreed that it seemed consistent with asthma, adjusted my inhaler, and sent me home.
But by Friday, I could barely function.
A friend urged me to go to the emergency room. I was hesitant. Still unsure, I listed my symptoms and asked ChatGPT for a recommendation. It told me, very directly, that I needed immediate medical attention and that my symptoms could point to something far more serious.
It was right.
After five days in the hospital and a thrombectomy to remove four large blood clots from my lungs, I am thankfully on the mend. And I was told very plainly upon discharge: if I had waited through the weekend, I might not have survived it.
That experience left an impression on me—and not only personally.
Because the lesson applies just as powerfully to trade compliance as it does to health: when something does not feel right, do not ignore it. Do not assume. And do not take comfort solely because someone, even an expert, once gave you an answer you wanted to hear.
Years ago, I saw this play out in the trade world. A company made a classification decision that created millions in duty savings. They sought outside expert review, and that expert agreed with the position in writing. It looked supported. It looked defensible. Until CBP saw it differently. The matter went through litigation and appeals, and in every instance the courts sided with CBP—not the importer. The result was catastrophic: repayment of duties, interest, penalties, enormous legal fees, and a lengthy focused assessment.
One assumption. One “confirmed” opinion. One devastating result.
That is the point.
Are there decisions sitting quietly inside your business today—classification positions, valuation methodologies, origin claims, broker instructions, qualification assumptions—that may feel settled, but would not withstand intense scrutiny tomorrow?
Now is the time to find out.
CBP is asking harder questions. The burden of proof is growing. The margin for error is shrinking. And as this week’s updates make clear—from ACE refund readiness, to portal modernization, to Jones Act guidance, to the continuing pace of trade and tariff actions—the environment is only becoming more demanding.
So let this be a gentle but serious reminder:
Assess yourself honestly.
Review the decisions you may have accepted too comfortably.
Pressure test the positions that could create real exposure.
And do not wait until a crisis forces the issue.
In health, delay can be dangerous.
In compliance, complacency can be costly.
I am grateful to still be here to write this message. I hope you will take it in the spirit in which it is offered—not as alarm, but as encouragement to pause, evaluate, and act while you still have the opportunity.
Let’s stay vigilant.
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 **
CSMS # 68179006 – REMINDER: ACE Portal Access and ACH Set-Up Required to Receive CBP Refunds
On February 6, 2026, U.S. Customs and Border Protection (CBP) transitioned to electronic-only refunds, as announced in the Electronic Refunds Interim Final Rule published January 2, 2026, in the Federal Register (91 FR 21). This change was necessitated by 31 U.S.C. § 3332 and President Trump’s March 25, 2025, Executive Order 14247, Modernizing Payments To and From America’s Bank Account, 90 FR 14001.
Since February 6, 2026, CBP has had over 12,300 certified refunds rejected because the recipient party did not provide CBP the necessary banking information. If a refund recipient has failed to provide CBP…
CSMS # 68179006 – REMINDER: ACE Portal Access and ACH Set-Up Required to Receive CBP Refunds
CSMS # 68228015 – New ACE Portal Account Application Now Available
On April 1, 2026, U.S. Customs and Border Protection (CBP) released a modernized ACE Secure Data Portal (ACE Portal) account application for the trade community. The new digital web form facilitates…
CSMS # 68228015 – New ACE Portal Account Application Now Available
| CSMS # 68180454 – Updated Guidance: Implementation of Jones Act Waiver issued to the Department of War, dated March 17, 2026U.S. Customs and Border Protection (CBP) is providing updated guidance to CSMS 68096516 – Implementation of Jones Act Waiver issued to the Department of War, dated March 17, 2026. This guidance includes an updated list of potentially covered products (attached) as of March 27, 2026. In addition, CBP clarifies its interpretation of the applicability of the waiver deadline |
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 Applications:
Facility-Specific Rapid Response Labor Mechanism Dispute Settlement Roster for the United States-Mexico-Canada Agreement
| FR Document: 2026-05898 Citation: 91 FR 14747 |
PDF Pages 14747-14748 (2 pages) Permalink |
| Abstract: The United States-Mexico-Canada Agreement (USMCA) requires the maintenance of a roster of individuals who would be available to serve as panelists for specialized labor panels. The Office of the United States Trade Representative (USTR) invites applications from eligible individuals wishing to be included on this roster. | |
Streamlining Foreign Trade Regulations
| FR Document: 2026-06133 Citation: 91 FR 15535 |
PDF Pages 15535-15536 (2 pages) Permalink |
| Abstract: By this rule, the Census Bureau is amending its foreign trade regulations by consolidating and streamlining certain cross-references to, and restatements of, other regulations and authorities. This action is intended to simplify and streamline the foreign trade regulations, and thereby promote efficiency, without affecting any substantive obligations or entitlements. | |
Publication of 2026 Tariff-Rate Quota Quantitative Limits Under the United States-Australia Free Trade Agreement
| FR Document: 2026-06207 Citation: 91 FR 16080 |
PDF Page 16080 (1 page) Permalink |
| Abstract: In accordance with the United States-Australia Free Trade Agreement entered into by the United States and the Commonwealth of Australia, the Office of the United States Trade Representative is providing notice of tariff-rate quota quantitative limits of certain tariff subheadings for calendar year 2026. | |
Request to Change End-user, End-use and/or Destination of Hardware and Open General Licenses
| FR Document: 2026-06209 Citation: 91 FR 16078 |
PDF Pages 16078-16079 (2 pages) Permalink |
| Abstract: The Department of State has submitted the information collection described below to the Office of Management and Budget (OMB) for approval. In accordance with the Paperwork Reduction Act of 1995 we are requesting comments on this collection from all interested individuals and organizations. The purpose of this Notice is to allow 30 days for public comment. | |
Antidumping or Countervailing Duty Investigations, Orders, or Reviews
| FR Document: 2026-06127 Citation: 91 FR 15951 |
PDF Pages 15951-15974 (24 pages) Permalink |
| Abstract: The U.S. Department of Commerce (Commerce) has received requests to conduct administrative reviews of various antidumping duty (AD) and countervailing duty (CVD) orders with February anniversary dates. In accordance with Commerce’s regulations, we are initiating those administrative reviews. | |
Polyethylene Terephthalate Film, Sheet, and Strip from India, Taiwan, the People’s Republic of China, and the United Arab Emirates
| FR Document: 2026-06007 Citation: 91 FR 14815 |
PDF Pages 14815-14816 (2 pages) Permalink |
| Abstract: As a result of determinations by the U.S. Department of Commerce (Commerce) and the U.S. International Trade Commission (ITC) that revocation of the antidumping duty (AD) and countervailing duty (CVD) orders on polyethylene terephthalate film, sheet, and strip (PET film) from India, Taiwan, the People’s Republic of China (China), and the United Arab Emirates (UAE) would likely lead to the continuation or recurrence of dumping, countervailable subsidies, and material injury to an industry in… | |
Hardwood and Decorative Plywood from China, Indonesia, and Vietnam
| FR Document: 2026-05849 Citation: 91 FR 14709 |
PDF Pages 14709-14712 (4 pages) Permalink |
| Abstract: The Commission hereby gives notice of the scheduling of the final phase of antidumping and countervailing duty investigation Nos. 701-TA-764-766 and 731-TA-1747-1749 (Final) pursuant to the Tariff Act of 1930 to determine whether an industry in the United States is materially injured or threatened with material injury, or the establishment of an industry in the United States is materially retarded, by reason of imports of hardwood and decorative plywood from China, Indonesia, and Vietnam,… | |
Chassis and Subassemblies from China
| FR Document: 2026-06292 Citation: 91 FR 16223 |
PDF Pages 16223-16226 (4 pages) Permalink |
| Abstract: The Commission hereby gives notice that it has instituted reviews pursuant to the Tariff Act of 1930, as amended, to determine whether revocation of the antidumping and countervailing duty orders on chassis and subassemblies from China would be likely to lead to continuation or recurrence of material injury. Pursuant to the Act, interested parties are requested to respond to this notice by submitting the information specified below to the Commission. | |
News from other esteemed sources:
This week a lot of good information has been shared from our friends at CSIS, and specifically in their trade related podcast The Trade Guys | CSIS Podcasts .
You can listen, and subscribe, at the link above, or find them wherever you get your podcasts from! (Apple Podcasts, Spotify, YouTube)
This week:
| SCOTUS Decision Check-in, U.S. Cuba Relations, and USMCA Updates |
| Bill and Scott discuss the SCOTUS ruling on the IEEPA tariffs one month after its decision, unpack the challenges and sanctions in the U.S.-Cuba relationship, and give an update on USMCA. SCOTUS Decision Check-in, U.S. Cuba Relations, and USMCA Updates | The Trade Guys | CSIS Podcasts |
| EU-Australia Trade Deal, Sanctions Relief for Russia and Iran, UK Steel Tariffs, and US-Ecuador Agreement |
| On this episode of the Trade Guys, Bill opens with an update on the ongoing 14th WTO Ministerial Conference and the legislative implementation of the EU-U.S. trade deal. Bill and Scott then dive into the completed EU-Australia trade deal, the Trump administration’s temporary pause on oil sanctions on Russia and Iran, new steel tariffs in the UK, and the new Agreement on Reciprocal Trade between the U.S. and Ecuador.EU-Australia Trade Deal, Sanctions Relief for Russia and Iran, UK Steel Tariffs, and US-Ecuador Agreement | The Trade Guys | CSIS Podcasts |
You also might be interested in:
| In the Shadows of the Iran War: The Horn of Africa |
| As the U.S.-Israel-Iran war intensifies, global attention is focused on the Middle East, but a profound geopolitical restructuring is unfolding along the Red Sea. For years, the Horn of Africa has been a critical arena for understanding global geopolitical competition and shifts, and the Iran war is exposing the risks and gaps that analysts had foreshadowed.In the Shadows of the Iran War: The Horn of Africa | Into Africa | CSIS Podcasts |
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 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.
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.
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 importance of the human component in using AI. Please view at: https://vigilantgts.com/ai-speed-human-judgment-fewer-penalties-hb/
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/