Customs

On March 31, 2026, Brandon Lord, the Executive Director of the U.S. Customs and Border Protection (“CBP” or “Customs”) Trade Programs Directorate, Office of Trade, filed a status update (the “Declaration”) with the Court of International Trade (“CIT”) further outlining Customs’ progress in developing the Consolidated Administration and Processing of Entries (CAPE) functionality within ACE. CAPE has four integrated components: Claim Portal, Mass Processing, Review and Liquidation/Reliquidation, and Refund.

On March 19, 2026, Brandon Lord, the Executive Director of U.S. Customs and Border Protection, filed a status update with the U.S. Court of International Trade (“CIT”) outlining CBP’s progress in developing a new Automated Commercial Environment (“ACE”) functionality intended to support refunds of tariffs that were imposed under the International Emergency Economic Powers Act (“IEEPA”).

Effective February 6, 2026, Customs and Border Protection (“CBP”) will issue refunds electronically via Automated Clearing House (“ACH”). This rule change will affect all refunds, subject to limited exceptions (e.g., certain emergency payments, transactions involving national security or law enforcement concerns, transactions involving individuals who do not have access to banking services or electronic payment systems, etc.). FR Document 2025-24171. Also this rule will apply to all importers, brokers, filers, sureties, service providers, facility operators, foreign trade zone operators, and carriers as well as designated third parties listed on a CBP Form 4811. In short, absent a waiver, after February 5, 2026 CBP will not issue refunds by check. 

Sign at the United States Department of Justice in Washington, D

In March 2025, in a similar blog post to this one, Nithya Nagarajan and Robert Romashko forecasted that False Claims Act (“FCA”) enforcement would increase under the current tariff-focused trade policy regime. Sure enough, the Department of Justice (“DOJ”) recently announced two FCA resolutions involving allegations of failure to pay customs duties and evasion of antidumping and countervailing duties.

Effective April 17, 2024, U.S. Customs and Border Protection (“CBP”) has amended its regulations implementing the Enforce and Protect Act of 2015 (“EAPA”), a statute granting increased authority to investigate allegations of evasion of antidumping and countervailing duty (“AD/CVD”) orders. The amendments were issued in a final rule of March 18, 2024, and they are…

    

On March 28, 2024, CC Metals and Alloys, LLC (“CCMA”) and Ferroglobe USA, Inc.(“Ferroglobe”) (“Petitioners”), filed a petition for the imposition of antidumping and countervailing duties on ferrosilicon from the Federative Republic of Brazil (“Brazil”), the Republic of Kazakhstan (“Kazakhstan”), Malaysia, and the Russian Federation (“Russia”).

SCOPE OF THE INVESTIGATION

The following language describes…