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October 2026

Call 305-456-3830 or email info@diaztradelaw.com.

What Happened This Month in International Trade (October 2026) 

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.  
By |2026-10-30T12:21:48-04:00October 30, 2026|news, Snapshot|0 Comments
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What Happens When CBP Audits Your Business? A Complete Guide for Importers 

Receiving notice of an audit from U.S. Customs and Border Protection (CBP) can raise serious concerns for any business importing merchandise into the United States. What records will CBP request? How far back will the agency investigate? Could your company face additional duties or penalties? 

A CBP audit is designed to evaluate whether an importer is complying with U.S. customs laws and regulations. Depending on the type and scope of the audit, CBP may examine import transactions, accounting records, internal procedures, and the systems a company uses to manage its customs compliance responsibilities. 

An audit does not automatically mean CBP suspects fraud or that penalties will follow. However, it can uncover errors that result in substantial financial exposure, particularly when those errors affect multiple shipments over several years. 

For importers, understanding the CBP audit process and preparing before an audit begins can make a significant difference. 

What Is a CBP Customs Audit? 

A CBP customs audit is a review of a company’s import activities to determine whether the business is meeting its obligations under U.S. customs laws. 

Unlike a routine examination of an individual shipment, a customs audit may involve a broader review of an importer’s operations, records, internal controls, and historical transactions. 

CBP’s Regulatory Audit function conducts audits under authorities that include 19 U.S.C. § 1509. Depending on the circumstances, an audit may evaluate whether an importer has properly: 

By |2026-10-29T13:07:36-04:00October 29, 2026|U.S. Customs and Border Protection (CBP)|0 Comments
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OFAC’s Extreme Networks Settlement: Why Screening Names Alone Is Not Enough 

On October 27, 2026, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced a $1,529,685 settlement with Extreme Networks, Inc. for nine apparent violations of the Ukraine-/Russia-Related Sanctions Regulations. The customer was a Russian missile and air defense manufacturer that was not on the SDN List when the transaction closed, but was deemed a blocked person by OFAC at all times by virtue of its majority owner being a a designated entity. Exporters, acquirers, and any company selling through foreign distributors in high-risk markets should test whether their screening looks past the name on the order. 

KEY TAKEAWAYS 

  • OFAC treated a Russian defense manufacturer as a blocked person at all relevant times because a designated Russian state-owned company held majority ownership, even though the manufacturer itself was not added to the SDN List until June 2022, after the conduct ended. 
  • According to OFAC, Extreme Networks’ U.S.-led compliance function reviewed the 2018 purchase agreement that named the manufacturer as an end user, and screened all nine later purchase orders, without identifying the blocked party. 
  • OFAC determined the nine apparent violations were egregious and voluntarily self-disclosed. The settlement is $1,529,685, against a base penalty of $1,699,650. 
  • OFAC’s compliance guidance in this case centers on three areas: sanctions diligence in acquisitions (including asset purchases), […]
By |2026-10-29T12:52:53-04:00October 29, 2026|U.S. Office of Foreign Assets Control (OFAC)|0 Comments
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Reporting Customs Fraud: A Guide to False Claims Act Whistleblower Claims 

Key Takeaways 

  • Individuals and businesses with information about customs fraud or tariff evasion may be able to file a whistleblower lawsuit under the federal False Claims Act (FCA). 
  • The FCA allows eligible whistleblowers to receive 15% to 30% of qualifying government recoveries, depending on whether the government intervenes and other statutory factors. 
  • Employees, former employees, competitors, customs brokers, and others with credible information about customs fraud may qualify as whistleblowers. 
  • Speaking with an attorney experienced in customs law and False Claims Act matters before reporting suspected fraud can help protect your rights and evaluate your potential eligibility for a reward. 

Can You Become a Whistleblower for Customs Fraud? 

If you know or suspect that a company is intentionally avoiding U.S. customs duties, you may have an opportunity to report the conduct and potentially receive a financial reward. The federal False Claims Act allows qualifying private parties to bring lawsuits on behalf of the United States against individuals or companies that knowingly defraud the government. 

Although the FCA is commonly associated with healthcare and government contracting fraud, it also applies to certain types of international trade fraud. 

For example, a company may violate the FCA by knowingly misrepresenting the value, classification, or country of origin of imported merchandise to […]

By |2026-10-27T12:17:56-04:00October 27, 2026|U.S. Customs and Border Protection (CBP), U.S. Department of Justice (DOJ)|0 Comments
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Breaking Trade News: 338 Lawsuit, Postal Rule Date Extended, No New 232 Tariffs on Wind Turbines

This week’s recap of the latest customs and international trade news:  

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. 

U.S. Customs and Border Protection (CBP) 

  • 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.
  • CBP officers in Norfolk, Virginia seized 2,772 ceramic sinks that bore a counterfeit certification mark. The shipment was appraised at $462,501 manufacturer’s suggested retail […]
By |2026-10-23T16:19:34-04:00October 23, 2026|news, Snapshot|0 Comments
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