Another busy month in international trade news. Here’s the roundup:   

Administration:    

  • President Trump issued an executive order implementing provisions of the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026. The order provides for a 500% additional duty on Russian-origin goods and 100% additional duties on goods from certain countries that purchase Russian oil or natural gas or facilitate sanctions evasion.  
  • In an October 22 proclamation, the Trump administration declined to impose additional Section 232 tariffs on wind turbines and their components despite findings that the imports pose a cybersecurity threat, leaving existing 50% Section 232 tariffs on applicable steel, aluminum, and copper products unchanged.  

Customs and Border Protection (CBP)         

  • Phase three of the Consolidated Administration and Processing of Entries (CAPE) refund system was deployed by CBP on October 6. Phase 3 covers finally liquidated entries from importers that filed suit at the CIT and for which the Court has ordered reliquidation.  
  • CBP issued a proposed rule that would create a framework for low-value imports after the end of de minimis and formally establishing new informal Entry Type 13 for merchandise entering through the mail. Comments are due December 7.  
  • CBP published a final rule in the October 22, 2026 Federal Register that moves the compliance date for the postal rule’s formal entry requirements from October 22, 2026, to January 20, 2027.  
  • CBP modified its Entry Type 13 test so filers can submit an electronic mail entry before their Partner Government Agency (PGA) data is complete. 

Court of International Trade       

  • On October 20, New Jersey-based food importer filed a lawsuit in the CIT challenging tariffs imposed on Canadian merchandise under Section 338 of the Tariff Act of 1930.  

Department of Justice (DOJ)  

  • On October 1, 2026, DOJ’s National Fraud Enforcement Division issued Directive 26-12, which makes trade fraud a corporate enforcement priority and lists ten factors prosecutors must weigh in deciding whether to charge a company.   
  • DOJ announced that a Bosnian national was sentenced to 60 months in federal prison after pleading guilty to export and sanctions violations involving an attempted transaction for North Korean anti-aircraft missiles. 

U.S. Trade Representative (USTR)

  • USTR announced a public consultation process ahead of the 2027 joint review of the United States-Mexico-Canada Agreement (USMCA). The agency is soliciting comments on the agreement’s operation and will hold a public hearing. Comments and requests to testify are due January 12, 2027.  
  • USTR announced that the 301 tariffs on China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation, that began in 2018, will remain in effect.  

U.S. Department of Treasury  

  • Treasury announced the first civil penalty ever issued under the Outbound Investment Security Program (OISP): $200,000 against Amidi LLC, the U.S. parent company of the organization known as Plug and Play Tech Center, for failing to notify Treasury of an investment its Chinese fund subsidiary made in a Chinese embodied artificial intelligence company.   
  • U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an Alert asking financial institutions to report potential Iranian regime abuse of religious charity networks, including diversion of religious tithes, or khums.   

Department of Homeland Security 

  • DHS announced the addition of three companies to its list of entities that may be using forced labor from the Xinjiang region of China. The total number of companies on the list is now 190.  

State Department  

  • The State Department announced sanctions against five Chinese entities under the Protecting American Intellectual Property Act of 2022 (PAIPA). The sanctions follow an investigation involving the theft of trade secrets.  

Bureau of Industry and Security (BIS)  

  • BIS announced that it reached an administrative enforcement settlement with Lambda Research Corporation involving alleged export control violations.   

Office of Foreign Assets Control (OFAC)   

  • OFAC announced a settlement with Pegasus Worldwide Logistics, a freight forwarding firm, to settle its potential civil liability for importing a machine supplied by a designated company.   
  • OFAC announced an $11,662,930 settlement with Bank of America to settle its potential civil liability for 475 apparent violations of OFAC sanctions programs targeting Russia, Belarus, Iran, Burma, Somalia, narcotics, and global terrorism.  
  • OFAC announced sanctions against four individuals and 11 entities connected to Cartel del Noreste.  

Federal Maritime Commission (FMC)  

  • The FMC issued an Order asking COSCO Shipping why they failed to pay an award to a complainant. The $24,329 award has gone unpaid for 223 days. The FMC could impose penalties of up to $16.7M for the delayed payment.   
  • A FMC judge ordered non-vessel-operating common carrier Top Shipping Systems (TSS) to pay a Florida-based importer more than $57,000 for withholding two containers in an attempt to obtain overdue payments.  
  • The FMC is proposing fees on all Spanish-flagged vessels after an investigation revealed the government of Spain created unfavorable shipping conditions for U.S.-flagged vessels.    

Food and Drug Administration (FDA)   

  • The FDA published a Federal Register notice with industry guidance on mandatory cosmetics recalls.  
  • The FDA issued six warning letters to companies for their failure to implement foreign supplier verification programs.  
  • The FDA announced its first major review of infant formula nutrient requirements   

since 1998, proposing updated standards to better support infant growth and development. The agency also released new contaminant testing data showing that most infant formula samples contained low or undetectable levels of chemical contaminants.  

Federal Communications Commission (FCC)  

  • The FCC’s Office of Engineering and Technology identified two devices to keep them from being marketed or sold in the U.S. because they contained a chip produced by a Covered List entity.  

Congress  

  • Kansas Representative Sharice Davids has called on the Small Business Administration (SBA) and CBP to help small businesses apply for refunds of tariffs imposed under the International Emergency Economic Powers Act (IEEPA).  
  • U.S. House Representative John James of Michigan introduced a bill to use tariff revenue to compensate businesses that can show they have suffered real economic harm from tariffs on Canadian imports or from Canadian retaliatory tariffs. 

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