The Vigilant Vigil – First Addition
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:
It’s exciting to launch the very first edition of The Vigilant Vigil.
If there’s one constant in global trade right now, it’s change. Tariffs shift, executive orders evolve, court decisions reset the landscape, and agencies issue updates at a pace that can make even the most seasoned compliance professional feel like they’re running to keep up. There is no shortage of information — in fact, there may be too much of it.
That’s why we created The Vigil.
Our goal is not to add to the noise, but to help distill it. In each edition, we’ll highlight key developments, point you toward primary sources, and offer practical considerations so you can take informed action. This first issue is a bit of a “taster” — a snapshot of the kinds of regulatory, enforcement, and trade updates we’ll be tracking together. There is much more we could say on each topic, and in future editions we will continue to expand our analysis and provide even more direct links and data sources to support your work.
Trade compliance demands vigilance. It demands preparation. And, increasingly, it demands community.
We’re especially looking forward to connecting with many of you at the ICPA Annual Conference in San Antonio, March 1–4. Whether you stop by booth #300, join the Voices of Compliance Choir, or attend the session on Customs Entry and Broker Audits, we hope to see you there and continue these conversations in person.
Thank you for joining us at the start of this new initiative. Let’s stay vigilant — together.
Jamie Adams, LCB, CCS
Director of Global Compliance Solutions at Vigilant GTS
In this volume, we’ll explore:
- Supreme Court (SCOTUS) Ruling on IEEPA Tariffs
- Important CSMS messages. This week IEEPA tariff endings and updates to 122
- ITA updates published in the Federal Register, which, this week, include antidumping or countervailing investigations, orders and reviews pertaining to aluminum and steel products from various countries.
- An OFAC update on Venezuelan oil and gas sanctions from global law firm Baker McKenzie
- Opportunities to connect with us, in person, are coming soon!
- Don’t miss our TRADE BUZZ (Powered by Vigilant) videos which are published each week.
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 origin of source material but simply compilating the information.**
Supreme Court of the United States (SCOTUS) Strikes Down IEEPA Tariffs
The instructions for refunds are not yet provided. However, it is time to ACT immediately! As outlined in our TRADE BUZZ video of 2/19/2026 at – https://www.linkedin.com/feed/update/urn:li:activity:7430323160283254784 prepare now by running ACE reports, collecting all the entry information, audit 100% of every line and detail, correct those entries first, then apply for refunds).
https://www.scotusblog.com/2026/02/supreme-court-strikes-down-tariffs/
President Trump announced a 10% universal tariff under Section 122 starting on February 23 in response to the SCOTUS decision. Additionally, he has determined that the suspension of duty free De Minimis treatment for all countries will continue.
Continuing the Suspension of Duty-Free De Minimis Treatment for All Countries
CSMS Updates
**The following are short summaries of the actual information provided by CSMS. To stay up to date with announcements and news, please register at: Cargo Systems Messaging Service | U.S. Customs and Border Protection**
CSMS # 67834313 – Ending Collection of International Emergency Economic Powers Act Duties
The purpose of this message is to provide guidance regarding the February 20, 2026, Executive Order (EO), “Ending Certain Tariff Actions,” that terminates the collection of the additional ad valorem duties imposed pursuant to the International Emergency Economic Powers Act (IEEPA).
Duties imposed pursuant to IEEPA under the following presidential actions, including all modifications and amendments, will no longer be in effect and will no longer be collected for goods entered for consumption or withdrawn from warehouse for consumption, on or after 12:00 a.m. eastern time on February 24, 2026:
https://content.govdelivery.com/accounts/USDHSCBP/bulletins/40b11c9
CSMS # 67852800 – Harmonized System Update (HSU) 2605
Harmonized System Update (HSU) 2605 was created on February 23, 2026, and contains 169 harmonized tariff records and 512 Automated Broker Interface (ABI) records.
HSU 2605 includes updates regarding the ending of certain tariff actions under the International Emergency Economic Powers Act (IEEPA) and updates to Section 122 of the Trade Act of 1974.
For guidance on Section 122 duties, please see Executive Order Imposing a Temporary Import Surcharge to Address Fundamental International Payments Problems and CSMS 67844987.
For more information on the International Emergency Economic Powers Act (IEEPA) updates, please see Executive Order Ending Certain Tariff Actions and CSMS 67834313.
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
United States-Mexico-Canada Agreement Automotive Rules of Origin: Economic Impact and Operation, 2027 Report
In accordance with section 202A(g)(2) of the United States- Mexico-Canada Agreement Implementation Act (“the Act”), the U.S. International Trade Commission has instituted Investigation No. 332-608, USMCA Automotive Rules of Origin: Economic Impact and Operation, 2027 Report, for the purpose of preparing the 2027 report.
| FR Document: 2026-03499 Citation: 91 FR 8521 |
PDF Pages 8521-8523 (3 pages) |
Antidumping or Countervailing Duty Investigations, Orders, or Reviews
The U.S. Department of Commerce has received requests to conduct administrative reviews of various antidumping duty (AD) and countervailing duty (CVD) orders with December anniversary dates. In accordance with Commerce’s regulations, we are initiating those administrative reviews.
| FR Document: 2026-03417 Citation: 91 FR 8186 |
PDF Pages 8186-8205 (20 pages) |
North American Free Trade Agreement: Binational Panel Review: Panel Decision
On February 19, 2026, the Binational Panel issued its Decision on the Redetermination on Remand in the matter of Certain Softwood Lumber Products from Canada: Final Affirmative Determination of Sales at Less Than Fair Value and Affirmative Final Determination of Critical Circumstances (Secretariat File Number: USA-CDA-2017-1904-03). The Binational Panel affirmed in part and remanded in part the Department of Commerce’s Redetermination on Remand.
| FR Document: 2026-03653 Citation: 91 FR 8829 |
PDF Page 8829 (1 page) |
Carbon and Certain Alloy Steel Wire Rod from Brazil, Indonesia, Mexico, Moldova, and Trinidad and Tobago
On the basis of the record, the United States International Trade Commission determines that revocation of the countervailing duty order on carbon and certain alloy steel wire rod from Brazil and the antidumping duty orders on wire rod from Brazil, Indonesia, Mexico, Moldova, and Trinidad and Tobago would be likely to lead to continuation or recurrence of material injury to an industry in the United States within a reasonably foreseeable time.
| FR Document: 2026-03608 Citation: 91 FR 8899 |
PDF Page 8899 (1 page) |
Certain Aluminum Foil from the People’s Republic of China
The Department of Commerce determines that countervailable subsidies were provided to certain exporters/producers of certain aluminum foil (aluminum foil) from the People’s Republic of China (China) during the period of review (POR) January 1, 2023, through December 31, 2023.
| FR Document: 2026-03205 Citation: 91 FR 7437 |
PDF Pages 7437-7439 (3 pages) |
Stainless Steel Bar from India
The U.S. Department of Commerce (Commerce) determines that certain producers/exporters of stainless-steel bar (SS Bar) from India made sales at prices below normal value during the period of review (POR), February 1, 2023, through January 31, 2024.
| FR Document: 2026-03103 Citation: 91 FR 7442 |
PDF Pages 7442-7444 (3 pages) |
News from other esteemed sources:
From Baker McKenzie:
02/16/2026
On February 13, 2026, as part of an ongoing series of sanctions-easing measures following the capture of Venezuelan President Nicolás Maduro in January 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued two…
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 say hello, so we can get to know you better!
Where we will be:
ICPA Annual Conference March 1-4
San Antonio, TX
Join us for a Fiesta of Global Trade! Stop by and see us at booth #300!
Learn all about Vigilant GTS and what makes us an up and comer in the world of trade compliance. You can even enter for a chance to win some un-beat-able prizes!
Vigilant and TRABEX are proud sponsors of the ICPA Voices of Compliance Choir. Jamie Adams is the Choir Director and contact him if you would like to be a part of it.
Jamie Adams will be speaking at 8:30am on Tuesday, March 3 on “Customs Entry and Broker Audits”. Please join this important discussion, in light of the dynamic tariffs and increasing enforcement.
CBP Trade and Cargo Security Summit, April 28 – 29
Dallas, TX
Jamie Adams will be attending sessions and happy to connect with you.
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 numbers. You do receive a 33% discount for singing with us.
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. You can see the library of previous videos on our website at: https://vigilantgts.com/webinars/
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 monthly Trade Buzz Webinars which will restart in late March.
- Most recent video:
- SCOTUS Decision on IEEPA Tariffs – https://www.linkedin.com/feed/update/urn:li:activity:7430323160283254784
- Vigilant at the Sprint 2026 ICPA Conference in San Antonio – https://youtu.be/ezivpPbExDg?si=y6OZiP24JU6xd0fr