THE VIGILANT VIGIL – 6TH 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 sixth edition of the Vigilant Vigil.
This week, the updates themselves tell a very clear story.
We are seeing continued expansion and refinement of Section 232 tariffs—now impacting aluminum, steel, and copper with new structures and rates . At the same time, Federal Register activity remains steady with investigations, reviews, and enforcement actions continuing across multiple industries . Add to that evolving OFAC guidance, DOJ expectations around disclosures, and the ongoing rollout of IEEPA refund processes—and one thing becomes obvious:
The environment is not stabilizing.
It is accelerating.
And in that acceleration, one requirement rises above all others:
Audit. Audit. Audit.
For years, many compliance programs relied on sampling—spot checks, periodic reviews, “good enough” visibility into a subset of entries. That approach made sense when the landscape was simpler and the margin for error was wider.
That is no longer the case.
Today, with layered tariffs (232, 301, 122), complex origin rules, sanctions exposure, and rapidly changing regulatory requirements, even small errors can compound quickly. And the reality is this—brokers are under pressure, systems are lagging behind regulatory changes, and error rates across entries are higher than most organizations realize.
Sampling will not catch that.
100% review is no longer a best practice—it is becoming a requirement.
And here’s the critical shift: this does not mean 100% manual review. That would be impossible at scale.
It means leveraging technology.
CBP is already doing this. They are using advanced analytics and AI-driven tools to identify anomalies, inconsistencies, and patterns that warrant scrutiny—leading to CF-28s, CF-29s, audits, and investigations.
So the question becomes:
Are you using the same level of sophistication to review your own data?
Modern compliance requires running your entries against defined rules—systematically, consistently, and at scale. Identify the outliers. Focus your human expertise where it matters. Let automation handle the volume.
Because the goal is not just to find errors—it is to find them before someone else does.
The good news is this: the tools exist. The capability is there. And with the right approach—combining automated audit technology with experienced human oversight—this level of control is achievable. It’s an approach we utilize at Vigilant, and one we see becoming foundational across the industry.
This is not about creating more work—it is about creating better visibility, stronger defensibility, and ultimately, greater confidence in your compliance program.
So as you read through this week’s updates, I would encourage you to reflect on one simple question:
Do you truly know what’s in your entries?
If the answer is anything less than a confident “yes,” now is the time to act.
Let’s stay vigilant—and proactive.
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 # 68290408 – Harmonized System Update (HSU) 2607
Harmonized System Update (HSU) 2607 was created on April 5, 2026, and contains 116 harmonized tariff records and 519 Automated Broker Interface (ABI) records.
This HSU contains updates pertaining to the Section 232 duties on imports of aluminum, steel, and copper effective April 6, 2026. For more information or guidance, please see proclamation Strengthening Actions Taken to Adjust Imports of Aluminum, Steel and Copper into the United States and CSMS # 68253075.
CSMS # 68253075 – GUIDANCE: Section 232 Duties on Imports of Aluminum, Steel, and Copper
In April 2, 2026, the President issued a Proclamation, “Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper into the United States,” under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862). This proclamation imposes 10-50% additional duties on the full customs value of certain imports of steel, aluminum, copper articles (metal articles) and their derivatives from all countries, effective April 6, 2026.
CSMS # 68253075 – GUIDANCE: Section 232 Duties on Imports of Aluminum, Steel, and Copper
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
Investigations; Determinations, Modifications, and Rulings, etc.:
Certain Video-Capable Electronic Devices, Including Smart Televisions, Monitors, and Components Thereof
| FR Document: 2026-06387 Citation: 91 FR 16743 |
PDF Pages 16743-16744 (2 pages) Permalink |
| Abstract: Notice is hereby given that a complaint was filed with the U.S. International Trade Commission on February 26, 2026, under section 337 of the Tariff Act of 1930, as amended, on behalf of InterDigital, Inc. of Wilmington, Delaware, InterDigital VC Holdings, Inc. of Wilmington, Delaware, and InterDigital Madison Patent Holdings SAS of France. A letter supplementing the complaint was filed on March 13, 2026. The complaint, as supplemented, alleges violations of section 337 based upon the… | |
Non-Oriented Electrical Steel From China, Germany, Japan, South Korea, Sweden, and Taiwan
| FR Document: 2026-06576 Citation: 91 FR 17306 |
PDF Pages 17306-17307 (2 pages) Permalink |
| Abstract: The Commission hereby gives notice of the scheduling of expedited reviews pursuant to the Tariff Act of 1930 (“the Act”) to determine whether revocation of the antidumping duty and countervailing duty orders on non-oriented electrical steel (“NOES”) from China, Germany, Japan, South Korea, Sweden, and Taiwan would be likely to lead to continuation or recurrence of material injury within a reasonably foreseeable time. | |
News from other esteemed sources:
BAKER/MCKENZIE
On March 20, 2026, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Iran-related General License U (“GL U”), “Authorizing the Delivery and Sale of Crude Oil and Petroleum Products…
Read more…
On March 30, 2026, the US Department of Justice (“DOJ”) National Security Division (“NSD”) announced updated guidance clarifying how companies should report voluntary self-disclosures (“VSDs”) of potential criminal…
Read more…
THOMPSON/HINE
On April 2, 2026, President Donald Trump issued a proclamation amending the rates, scope, and administration of the Section 232 tariff regimes for aluminum, steel, and copper and their derivative products… The proclamation restructures the application of the Section 232 metal tariffs by dividing covered products across two annexes that carry different duty rates, effective April 6, 2026.
…the United States will impose on July 31, 2026, a 100% Section 232 tariff on imports of certain pharmaceuticals and associated active pharmaceutical ingredients (“APIs”). The tariff will operate as a floating rate…
CIT Endorses Phase 1 of the IEEPA Tariff Refund Process Ahead of CBP’s April 20 Rollout | SmarTrade
On April 1, 2026, Senior Judge Richard Eaton of the U.S. Court of International Trade (“CIT”) issued an order in Atmus Filtration, Inc. v. United States… concluding that the government “continues to make satisfactory progress” and “is on track to meet the April 20, 2026 deadline” for implementing Phase 1 of the refund process. Although Judge Eaton endorsed CBP’s anticipated rollout of Phase 1, a March 31, 2026 declaration makes clear that the initial phase will be limited in scope…
(In a separate order issued last week, Judge Eaton confirmed that the refund process must cover finally liquidated entries, see Update of March 30, 2026.)
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 regarding the importance of Brokerage Entry Audits – https://vigilantgts.com/smarter-import-audits-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/