THE VIGILANT VIGIL – 8TH 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 eighth edition of the Vigilant Vigil.
If it feels like trade compliance is becoming more complex by the week, that’s because it is. The rollout of the CAPE system for IEEPA refunds, continued tariff activity, and a steady cadence of enforcement actions all point in the same direction—this environment is accelerating, not stabilizing . And when you layer in the administration’s clear prioritization of enforcement funding, along with looming 2028 Harmonized Tariff Schedule changes that could be among the most significant we’ve seen in decades, it becomes clear: the complexity we’re managing today is only the beginning .
Which brings me—yes, once again—to a familiar refrain:
Audit. Audit. Audit.
I know I sound like a broken record. But in a moment like this, repetition isn’t redundancy—it’s necessity.
There’s understandable excitement around CAPE and the opportunity to recover IEEPA duties. It’s a meaningful development, and importers should absolutely be considering it. But as Su Ross aptly pointed out in a recent discussion, the more important question isn’t just can you file—it’s should you?
If your entries are fully vetted, supported, and correct—classification, origin, valuation, tariff application, and all—then by all means, go get what’s owed to you. But if that work hasn’t been done, then what you’re submitting isn’t just a refund request. It’s an attestation.
And that attestation carries weight.
You are formally affirming that your entries are accurate and compliant with U.S. law. If they’re not, you’re no longer just dealing with CBP penalties—you’re potentially stepping into False Claims Act exposure, where civil and even criminal liabilities can quickly escalate.
In other words, submitting unaudited data isn’t bold—it’s risky.
CBP has made it clear they will be reviewing these submissions, and given the sophistication of their data analytics today, it would be unwise to assume anything slips through unnoticed. The idea that one can simply upload a file and wait for a check is, at best, optimistic—and at worst, problematic.
This is why the fundamentals matter now more than ever. Not sampling. Not assumptions. Not “it’s probably fine.” But full visibility into your entries and full confidence in what you’re submitting.
The good news is that this level of control is achievable. The tools exist. The data is there. And with the right approach—whether internal or supported—you can get to a place where compliance decisions are not just hopeful, but defensible.
Because at the end of the day, this isn’t just about recovering duties.
It’s about protecting your business while you do.
So as you work through this week’s updates, my advice is simple:
Don’t let the urgency to recover funds outweigh the discipline to get it right.
Get it right first. Then go get it back.
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 # 68396594 – AVAILABLE NOW – Consolidated Administration and Processing of Entries (CAPE) for IEEPA Refunds
U.S. Customs and Border Protection (CBP) has activated the first phase of the Consolidated Administration and Processing of Entries (CAPE) tool in the Automated Commercial Environment Secure Data Portal (ACE Portal). Importers and authorized customs brokers can now file their CAPE Declarations through their ACE Portal accounts.
CSMS # 68397097 – Updated ACE Entry Summary Error Dictionary Now Available on CBP.gov
U.S. Customs and Border Protection (CBP) has published an updated ACE Entry Summary Error Dictionary. The updated version includes a new validation error that occurs when a filer attempts to file a post-summary correction (PSC) for an entry for which a Consolidated Administration and Processing of Entries (CAPE) declaration has been submitted.
CSMS # 68397097 – Updated ACE Entry Summary Error Dictionary Now Available on CBP.gov
CSMS # 68370692 – Updated Guidance #2: Implementation of Jones Act Waiver issued to the Department of War, dated March 17, 2026
U.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
Sanctions Action
| FR Document: 2026-07699 Citation: 91 FR 21369 |
PDF Pages 21369-21370 (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) | |
Recommended Modifications in the Harmonized Tariff Schedule
| FR Document: 2026-07753 Citation: 91 FR 21311 |
PDF Pages 21311-21312 (2 pages) Permalink |
| Abstract: The Commission is seeking comments from interested Federal agencies and the public regarding proposed Commission recommendations to the President with respect to modifications to the U.S. Harmonized Tariff Schedule (HTS). The modifications would conform the HTS to recommended amendments adopted by the World Customs Organization (WCO) and that are scheduled to enter into force on January 1, 2028. | |
Non-Oriented Electrical Steel from Sweden, Germany, the People’s Republic of China, the Republic of Korea, Taiwan and Japan
| FR Document: 2026-07464 Citation: 91 FR 20407 |
PDF Pages 20407-20408 (2 pages) Permalink |
| Abstract: The U.S. Department of Commerce (Commerce) finds that revocation of the antidumping duty (AD) orders on non-oriented electrical steel (NOES) from Sweden, Germany, the People’s Republic of China (China), the Republic of Korea (Korea), Taiwan, and Japan would be likely to lead to continuation or recurrence of dumping, at the levels indicated in the “Final Results of Sunset Reviews” section of this notice. | |
News From Other Esteemed Sources:
ST&R (Sandler, Travis & Rosenberg):
Trade Enforcement Gets Funding Boost in President’s Proposed Budget
April 20, 2026 // Trade Report
Presidential budget proposals offer a clear window into each administration’s priorities, and the fiscal year 2027 proposal released April 3 by the White House sends a strong signal that trade enforcement will remain a central focus for the Trump administration.
The proposal would increase funding for several trade- and tariff-related agencies. Most notably…
Why Now is a Critical Time to Do an Import Compliance Review
April 17, 2026 // Trade Report
Importers continue to take a variety of measures to mitigate the impact of sudden and significant tariff increases, supply chain disruptions, and other trade-related challenges. However, U.S. Customs and Border Protection has intensified its scrutiny of those measures, which could lead to investigations, audits, and even penalties. Importers should therefore be conducting their own evaluations to ensure they are protecting duty savings and acting in compliance with applicable laws and regulations.
Why Now is a Critical Time to Do an Import Compliance Review | Sandler, Travis & Rosenberg, P.A.
False “Made in USA” Claims Net Enforcement Action
April 21, 2026 // Trade Report
Just a month after President Trump issued an executive order directing the Federal Trade Commission to prioritize enforcement of its “Made in USA” rule, the FTC announced the enforcement actions noted below.
The FTC rule prohibits marketers from labeling products as “Made in USA” unless (1)…
False “Made in USA” Claims Net Enforcement Action | Sandler, Travis & Rosenberg, P.A.
CSIS-THE TRADE GUYS:
Hormuz Blockade Impacts and Trump’s New Tariff Playbook
On this episode of the Trade Guys, Bill and Scott unpack the latest on the economic impacts of the blockade of the Strait of Hormuz. They also look at the Trump administration’s efforts to implement tariffs under Sections 122 and 301.
Hormuz Blockade Impacts and Trump’s New Tariff Playbook | The Trade Guys | 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 reviewing the importance of Mill Certificates and other data to support your Section 232 claims. https://vigilantgts.com/prove-origin-prevent-costly-tariffs-hb/
Check back with us every Tuesday as we will be publishing new quick topic videos every week.
You can see the library of all our videos on our website at: https://vigilantgts.com/webinars/