News Articles

CBP Supply Chain Compliance

CBP Asks for Comments On Supply Chain Compliance by 12/1/2026

CBP issued an Advance notice of proposed rulemaking, “Heightened Import Disclosures for Supply Chain Visibility,” 91 Fed Reg 56408 (FRN), on September 2, 2026. Responses are due to CBP by December 1, 2026, using the Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions for submitting comments via docket number USCBP–2026–1058.

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Trade Fraud

Lực Lượng Chống Gian Lận Thương Mại: Kỷ nguyên mới của việc siết chặt kiểm soát thương mại

Vào ngày 25 tháng 8 năm 2026, U.S. Department of Justice (DOJ) đã phối hợp với U.S. Department of Homeland Security (DHS) và U.S. Customs and Border Protection (CBP) để ra mắt Lực Lượng Chống Gian Lận Thương Mại (Trade Fraud Task Force). Lực lượng này đóng vai trò quan trọng trong chính sách siết chặt việc kiểm soát hành vi trốn thuế quan, gian lận hải quan và các hình thức buôn lậu theo Tariff Act of 1930, False Claims Act (FCA), cũng như các quy định về gian lận thương mại và âm mưu phạm tội thuộc Title 18.

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Trade Fraud

Trade Fraud Task Force: A New Era of Trade Enforcement

On August 25, 2025, the U.S. Department of Justice (DOJ) launched the Trade Fraud Task Force (Task Force) in collaboration with the U.S. Department of Homeland Security (DHS) and the U.S. Customs and Border Protection (CBP). The cross-agency Task Force is a crucial part of the Administration’s enforcement agenda against tariff evasion, Customs fraud, and smuggling schemes under the Tariff Act of 1930, the False Claims Act (FCA), and Title 18’s trade fraud and conspiracy provisions.

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Duty Drawback

Duty Drawback and Commingled Returns: CBP Approves an Accounting Method Solution

Unused merchandise drawbacks allow a claimant to recover up to 99% of the duties paid on imported goods that are exported, unused, within five years of importation. For importers of apparel, footwear, eyewear, and accessories, customer returns complicate that recovery. Once a product has been sold at retail and is returned, United States Customs and Border Protection (CBP) treats it as merchandise that may have been used for its intended purpose, and its new appearance does not prove otherwise.

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Section 232 Iron

Section 232 and Iron: What CBP’s New Guidance Means for Your Imports – The Difference Between Steel and Iron Has Never Mattered More

We are operating in one of the most volatile trade environments in recent memory. Tariff policy is shifting faster than most compliance programs can absorb. In that context, CBP’s March 15 guidance on Section 232 content value is not just a technical update. It brings meaningful clarity and importers who move quickly may find real money on the table.

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301 Tariffs

Section 301 Tariffs: A New Phase in U.S. Trade Policy

The resurgence of Section 301 tariff investigations marks a pivotal shift in U.S. trade policy. Following the Supreme Court’s invalidation of tariffs imposed under the International Emergency Economic Powers Act (IEEPA), the Office of the U.S. Trade Representative (USTR) has turned to Section 301 of the Trade Act of 1974 as a more durable legal pathway to reimpose and potentially expand tariff measures.

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AI Legislation

AI Legislative Framework Proposed by the White House

On March 20, 2026, the Trump Administration announced that it, “is committed to winning the AI race to usher in a new era of human flourishing, economic competitiveness, and national security for the American people.“ The White House issued a new comprehensive national legislative framework that addresses six key objectives.

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IEEPA

Supreme Court Clarifies Separation of Powers in IEEPA Tariffs Decision

In the final analysis, this case stands as one of the most important separation of powers decisions in the economic domain in U.S. history. It clarifies that tariffs are a form of taxation reserved to Congress, embeds the major questions doctrine in trade law, and reasserts the structural boundary between legislative and executive authority.

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Canada Carney

Goodbye USA – Canadian Prime Minister Mark Carney’s MiddlePowers Playbook is Officially in Play, Part 2

One of my recently published articles covered the World Economic Forum Davos speech by Canadian Prime Minister Mark Carney, where he summoned the middle powers of the earth to unite against the US forces who are demanding that they take a knee and capitulate, per Governor Newsom who was in attendance handing out knee pads. (Really) Well, to say the least, that’s not happening by even the longest stretch of anyone’s imagination.

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CTPAT Investigation

Keeping the Chain Secure: A Deep Dive into the Latest CTPAT Investigation

The global supply chain is the backbone of the U.S. economy, moving millions of tons of cargo daily. To keep things running smoothly and safely, U.S. Customs and Border Protection (CBP) place a significant reliance on the Customs Trade Partnership Against Terrorism (CTPAT). This voluntary program trades “gold star” benefits—like fewer inspections, business resumption priority, and faster border crossings—for a company’s commitment to high-level security.


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Statute of Limitations

CBP Statute of Limitations Waivers – Overview of Issues and Operation

Many trade practitioners that have had experience with a CBP prior disclosure or penalty action have encountered a request by CBP to execute a Statute of Limitations (SOL) waiver. These are usually accompanied by a request for the importer to provide a corporate resolution or the equivalent evidencing the authority of the SOL waiver signatory to sign the waiver on behalf of the importer / company.

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