Host: Cindy Allen

In this week’s episode of Simply Trade: Cindy’s Version, Cindy Allen examines a series of significant developments that continue reshaping the trade landscape—from ongoing IEEPA litigation and Section 122 court challenges to growing uncertainty surrounding USMCA negotiations.

But the heart of the episode focuses on the administration’s Executive Order on Strengthening Customs Enforcement and the concerns emerging as the trade community begins to digest its potential consequences. Cindy breaks down three areas drawing particular attention: escalating bond requirements, restrictions on foreign importers of record, and new ownership disclosure requirements.

Using Taylor Swift’s The Black Dog as a backdrop, Cindy reflects on the idea that some longstanding trade practices may be coming to an end. While CBP views many of these changes as necessary tools to combat transshipment, shell companies, and duty evasion, the trade community is grappling with the possibility that enforcement-focused reforms may also affect legitimate importers and trusted traders.

As Cindy notes, some old habits may indeed be "dying screaming"—but the larger question is what replaces them.

• The Court of Appeals indicated that Section 122 tariffs are likely lawful while litigation continues

• CBP confirmed IEEPA refunds continue to be processed and announced reconciliation entries will be eligible for CAPE beginning June 29

• CBP reiterated that it believes court direction is needed before refunding finally liquidated entries

• House Agriculture Committee hearings highlighted strong support for continued USMCA trade integration

• Debate over the future of the Jones Act continues as some groups push for its repeal

• Trade associations continue analyzing the Executive Order on Strengthening Customs Enforcement

This week's episode centers on three major concerns emerging from the Executive Order on Strengthening Customs Enforcement.

First, Cindy discusses the growing pressure surrounding customs bonds. As duty exposure increases, bond amounts are reaching unprecedented levels, creating challenges for importers and sureties alike. Questions remain regarding how CBP intends to apply mitigation limitations and whether liquidated damages could be affected.

Second, the Executive Order's language regarding foreign importers of record has generated uncertainty throughout the trade community, particularly among Canadian companies that have historically operated under long-established customs practices.

Finally, ownership disclosure requirements raise new questions about how CBP intends to evaluate importer eligibility and whether foreign ownership percentages could influence future customs treatment.

While many support stronger enforcement against bad actors, Cindy emphasizes that additional clarification is needed to ensure legitimate importers are not unintentionally caught in the process.

• Section 122 tariff collections will continue while litigation proceeds

• Reconciliation entries become eligible for CAPE beginning June 29

• CBP maintains that liquidated entries require court direction before refunds can be issued

• USMCA negotiations appear likely to continue beyond the upcoming review deadline

• Bonding requirements are becoming increasingly burdensome for some importers

• Foreign importer of record restrictions may have significant implications for Canadian trade

• Ownership disclosure provisions remain one of the least understood portions of the Executive Order

• The trade community continues seeking clarity on how enforcement reforms will be implemented

• Global Training Center

• Trade Force Multiplier

• United States Court of Appeals for the Federal Circuit

• Jones Act

• USMCA

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