Simply Trade

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Guest(s): Justin Dillon

Could your company be connected to forced labor without knowing it? In this episode of Simply Trade, hosts Lalo Solorzano and Andy Shiles welcome Justin Dillon, founder of FRDM, for a conversation about the people behind the products—and the responsibilities that come with buying, sourcing, and importing them.

Justin explains how forced labor concerns have moved from corporate philanthropy into sourcing, trade compliance, and business operations. Together, they explore what importers should consider before selecting suppliers, why procurement and compliance teams need to work together, and how supply chain visibility can help companies ask better questions before goods reach the border.

The discussion also goes beyond policies and paperwork. Justin shares the experiences behind his documentary work and advocacy, discusses FRDM’s relationship with WiseTech Global, and points listeners toward organizations supporting people affected by exploitation.

At the center of the episode is a compelling idea: meaningful change does not have to depend on a special campaign or a charitable budget. It can begin with everyday purchasing decisions. For trade professionals and business leaders, this conversation offers a reason to look more closely at where products come from—and what responsible sourcing should look like in practice.

Justin traces the shift from corporate social responsibility initiatives to supply chain due diligence and import enforcement. The discussion emphasizes early supplier vetting and collaboration among purchasing, trade compliance, legal, operations, and leadership—not waiting until a shipment encounters problems at the border.

Justin shares the context behind the rescue footage discussed in the episode and explains why recognizing exploitation is not always straightforward. Rather than encouraging listeners to conduct their own investigations, the conversation focuses on transparency, established reporting channels, and supporting local organizations already doing the work.

Justin challenges reliance on supplier questionnaires and one-time audits, advocating instead for data- and AI-driven supply chain mapping followed by deeper supplier participation. He also discusses FRDM and WiseTech Global, the influence of procurement spending, and his goal of making human rights a routine business consideration rather than an occasional campaign.

• Start before onboarding. Evaluate supply chain risks before committing to suppliers, when changing direction is less disruptive.

• Bring the right teams together. Responsible sourcing requires coordination across procurement, compliance, legal, operations, and executive leadership.

• Look beyond the first supplier relationship. Justin advocates mapping supply chains and asking suppliers to extend that visibility through their own networks.

• Put purchasing power to work. Align supplier expectations with company values, while supporting established organizations and reporting channels when concerns arise.

• Global Training Center — Presenter of Simply Trade and trade compliance education resources.

• Justin Dillon on LinkedIn — Connect with this episode’s guest.

• FRDM — The supply chain risk, mapping, and compliance technology discussed by Justin. frdm.ai

• WiseTech Global — The company discussed in connection with FRDM’s expansion.

• WiseTech Global’s FRDM acquisition announcement — Official background on the transaction discussed in the interview. wisetechglobal.com

• Made in a Free World — The nonprofit Justin recommends for supporting projects that help rescue and care for people affected by slavery and exploitation. madeinafreeworld.com

• Call & Response — Full Documentary — The full documentary link supplied for this episode. YouTube

• FRDM YouTube Channel — Additional videos from FRDM.

• Justin Dillon on CNN’s Quest Means Business — The additional interview supplied for this episode. YouTube

• National Human Trafficking Hotline — In the United States, call 1-888-373-7888 or text 233733 (BEFREE) for assistance or to report a potential trafficking situation. For immediate danger, call 911. National Human Trafficking Hotline

These links provide additional reference material; not every resource below was named individually during the conversation.

• U.S. Customs and Border Protection — Forced Labor — Official starting point for forced-labor enforcement information and importer resources. GovDelivery

• CBP — Uyghur Forced Labor Prevention Act Overview — Background on the UFLPA and its import restrictions. CBP Help

• European Commission — Forced Labour Regulation — Official information on the EU framework. The product prohibition applies from December 14, 2027. single-market-economy.ec.europa.eu

• UK Government — Transparency in Supply Chains: A Practical Guide — Modern slavery reporting and supply chain transparency guidance for businesses. GOV.UK

• Australian Government — Modern Slavery Act — Official background on Australia’s modern slavery reporting framework. Attorney-General's Department

• Public Safety Canada — Forced Labour in Canadian Supply Chains — Guidance and reporting resources under Canada’s Supply Chains Act. Public Safety Canada

• Canada Border Services Agency — Goods Manufactured or Produced by Prison or Forced Labour — Background on Canada’s import prohibition. Canada Border Services Agency

• Mexico’s STPS — Forced Labor Import Restrictions — Official information on Mexico’s mechanism for investigating and restricting imports produced with forced labor. Resource in Spanish. Trabajo Forzoso

• CBP Forced Labor Allegation Portal — An additional resource, not named in the episode, for submitting allegations involving forced labor in imported goods. GovDelivery

These organizations came up during the discussion of corporate volunteering, philanthropy, and business models; they were not presented as trafficking-response resources.

• Habitat for Humanity — Referenced by Andy as an example of organized corporate volunteering.

• Anthropic — Mentioned briefly by Justin during the discussion of philanthropy and business models.

The individual local organizations described in India and Ghana were not identified by name in the transcript.

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Host: Lalo Solorzano

Your Mexican customer asks for a purchase agreement—even though you have been doing business for years using purchase orders and invoices. Why the extra paperwork?

In Episode 5 of 90 Days Until 2027, Lalo Solorzano welcomes back Miriam Name to explore how U.S. exporters can support their Mexican customers’ compliance efforts. After a lighthearted Día de los Muertos opening, the conversation turns to a serious question: can the importer document what happened throughout the transaction and support the value declared?

Miriam discusses purchase-agreement requests that are catching some U.S. sellers off guard, the commercial details those agreements should address, and the complications that rebates and deductions can create. Lalo also asks how the documentation changes when the relationship involves manufacturing services or a sale between related companies.

The goal is not to turn every request into a renegotiation of an established business relationship. Miriam offers a practical approach for connecting existing purchase orders, commercial documents, and terms through a master agreement.

This week’s tip puts cooperation first. Before treating a request as unnecessary paperwork, understand what your Mexican counterpart needs to support—and how your team can help keep the relationship moving forward.

Supporting Mexican customs valuation starts with understanding the transaction—not just sending the invoice.

Miriam frames the discussion around traceability and materiality: documentation showing that a transaction occurred, how it was carried out, and why the declared value is supportable. That includes evidence of the commercial relationship, delivery, transportation, and payment responsibilities.

She describes requests for purchase agreements identifying the parties, tax identification, company addresses, the applicable Incoterm, delivery arrangements, and who pays for transportation. The conversation also explores how rebates, deductions, and year-end adjustments can complicate the connection between commercial pricing and Mexican import declarations.

The appropriate documentation depends on the arrangement. Miriam distinguishes sales transactions from pure maquila arrangements supported by a maquila services agreement. She also discusses related-party sales and the role of transfer-pricing analysis in supporting value.

Her closing recommendation is to cooperate with the importer on a master agreement that references existing purchase orders, commercial documents, and terms—rather than assuming the request requires starting every negotiation over.

• Do not dismiss the agreement request. Miriam urges U.S. exporters to take Mexican customers’ documentation requests seriously, even when the relationship has operated through purchase orders and invoices for years.

• Make the commercial details clear. The information Miriam identifies includes company names and addresses, tax identification, the applicable Incoterm, delivery terms, and responsibility for transportation costs.

• Pay attention to rebates and deductions. Miriam explains that these arrangements can complicate support for customs value. She also discusses the potential need to adjust Mexican import declarations, or pedimentos, when the value changes.

• Match the agreement to the relationship. Sales, pure maquila arrangements, and related-party transactions raise different documentation questions. Miriam discusses master agreements, maquila services agreements, and transfer-pricing support—not one document that automatically fits every situation.

• Global Training Center

• Miriam Name — LinkedIn

• Cacheaux, Cavazos & Newton (CCN)

• IMMEX Blog Post

Follow Simply Trade for updates on companion resources and the 90 Days Until 2027 playbook.

This episode provides general educational information and is not legal advice. Confirm the documentation and valuation requirements applicable to your specific transaction.

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Host: Cindy Allen

Who stays to do the work after the party is over? In this episode of Simply Trade: Cindy’s Version, Cindy Allen uses Taylor Swift’s “New Year’s Day” to explore a question every importer should ask: what makes a customs broker a true partner when trade requirements change?

In her October 30 trade update, Cindy discusses Canadian Section 338 tariff litigation, CAPE refund developments, USTR activity, and enforcement concerns affecting the trade community. She then turns from the headlines to the people responsible for putting changes into practice—especially Northern Border customs brokers managing the tariff changes described in the episode.

The focus is not just on filing entries. It is on identifying affected clients, working through complex duty-treatment questions, coordinating entry and entry-summary timing, and communicating when decisions cannot wait. Cindy highlights the preparation and judgment behind that work, including the limits of automated tools when the details get complicated.

For importers, brokers, and compliance teams, this episode is a reminder to look beyond the visible transaction. The strongest partnerships are built on the quieter work that keeps both sides informed, prepared, and aligned long after the announcement lands.

• Section 338 litigation and CAPE refunds: Cindy reviews the challenge to Canadian tariffs, CAPE 3 developments involving protested entries, and the plaintiffs’ request for a CAPE 4 process covering antidumping and countervailing duty entries.

• USTR and Section 232 reviews: The roundup includes expected recommendations from the Section 301 overcapacity investigations, Airbus subsidy concerns, and the outcome Cindy reports from the robotics and industrial machinery review.

• Capitol Hill and Russian fuel imports: Cindy discusses political criticism of Canadian tariff adjustments and warnings to banks, ports, and fuel distributors about their involvement in Russian fuel imports.

• FMC enforcement: Cindy highlights increased scrutiny of ocean transportation intermediaries and the importance of having processes and procedures ready to address regulatory inquiries.

Cindy uses “New Year’s Day” as a metaphor for the work that happens outside the spotlight: preparation, coordination, and follow-through when tariff changes create difficult operational questions.

Her focus is on Northern Border customs brokers navigating the changes discussed in the episode. Identifying affected shipments is only the beginning. Brokers must also work through duty-treatment details, entry and entry-summary timing, and client communication—tasks Cindy explains cannot always be handled through automated tools alone.

The question for importers: who is prepared to work alongside you when the details become complicated, not just when everything is running smoothly?

• Look beyond the filing. A broker’s value includes the preparation, analysis, and communication that happen before an entry is submitted.

• Timing deserves close coordination. Cindy highlights how tariff transitions can raise questions about shipment timing, entry processing, and entry-summary filing.

• Reports do not replace judgment. Identifying affected transactions is different from resolving the complex duty-treatment questions behind them.

• Make the quiet work visible. Importers should recognize their brokers’ behind-the-scenes contributions, and brokers should communicate the work involved in supporting their clients.

• Global Training Center

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Host: Lalo Solorzano and Andy Shiles

Your trade team is getting more attention—but is it getting the resources, authority, and technology to match?

Lalo Solorzano and Andy Shiles welcome Julie Ann Parks of Altana and Eugene Laney Jr., Ph.D., of the American Association of Exporters and Importers (AAEI) to explore what it takes to move from constant firefighting to genuine trade readiness. Drawing on the joint Altana–AAEI report, The State of Enterprise Trade & Customs Organizations, the conversation examines the gap between growing expectations and the support available to meet them.

The discussion goes beyond keeping shipments moving. Where should trade compliance sit within an organization? What information should teams have before goods reach the border? And how can compliance leaders make a stronger business case for investment?

Julie and Eugene connect those questions to practical challenges: scattered product data, legacy systems, limited budgets, and uncertainty about AI. They also explain why automation should create room for human judgment—not replace it.

The episode closes with actionable “figure it out” advice for testing readiness, understanding the business impact of an enforcement response, and finding internal allies. For trade professionals preparing a resource request—and executives evaluating one—this conversation offers a starting point for turning compliance pressure into a more strategic role.

The episode centers on using trade-readiness research to build a business case for change. The linked Altana–AAEI report surveyed 230 enterprise trade leaders: 51% of teams did not meet its trade-readiness threshold, while only 26% felt their resources had grown enough to keep pace. Altana

Julie and Eugene explore how reporting structures, budget authority, and access to product and supplier information influence a team’s ability to prepare before goods move. The conversation also tackles AI adoption, with an emphasis on automating mechanical work while retaining expert review. Their practical challenge: simulate a detention or CF-28 response, document the effort and business impact, and use that evidence to explain what needs to change.

• Move decisions ahead of the shipment. Julie emphasizes resolving product and compliance questions before goods are moving, rather than making last-minute intervention the default operating model.

• Make the business case in terms leadership understands. Connect resource requests to cycle times, sourcing decisions, tariff mitigation, and the costs of responding to enforcement—not just the compliance team’s workload.

• Give trade information a reliable home. The discussion highlights the need to bring product attributes, supplier relationships, and compliance information together rather than continually chasing answers across disconnected systems and spreadsheets.

• Pair technology with expertise and internal allies. Automate repeatable work, retain human validation, and involve IT in compliance education. Eugene also encourages identifying the people who can help communicate the program’s value to executive leadership.

• Global Training Center

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Host: Lalo Solorzano

The shipment cleared customs. The goods were delivered. That means the entry is finished, right? Not so fast.

In Episode 4 of 90 Days Until 2027, Lalo Solorzano welcomes Global Training Center instructor Ashley Arnold with a reminder: customs release is not the end of the entry life cycle. Her year-end tip is to review what happened during the rush to get shipments moving—and address the issues that may still need attention.

Ashley explains why importers working with multiple brokers should compare classifications, run ACE reports, and confirm that supporting documents are actually available. She also encourages listeners to include DDP shipments in their review rather than overlooking them once the goods have arrived.

The discussion explores how a newly understood requirement or an incorrect Chapter 99 number can lead a team back to earlier entries. A review may reveal a problem to correct or a potential duty-recovery opportunity, but timing matters.

For teams already stretched thin, Ashley offers a manageable starting point: an entry number, an issue, and someone responsible for following through. This episode is about turning a year-end check into a repeatable habit—not adding another overwhelming project to your list.

Review the entry—not just the shipment’s delivery status.

Lalo and Ashley discuss a year-end review of entry data, broker classification consistency, and supporting records. Ashley recommends using ACE reports to look for discrepancies and checking other entries when an issue appears in one. They also discuss post-summary corrections, protests, and why identifying a potential correction or recovery opportunity is only useful when the applicable deadlines receive attention.

To keep the work manageable, Ashley shares her three-column approach: entry number, issue, owner. Assign responsibility, communicate the deadline, and follow up. The conversation also covers their expectations of closer supply-chain scrutiny and Ashley’s encouragement to ask questions and participate in public-comment opportunities.

• Customs release is not the finish line. Ashley urges importers to revisit entries, run ACE reports, and compare classifications across brokers instead of treating delivery as the end of the review.

• One error deserves a broader look. Finding an incorrect Chapter 99 number or learning that a requirement was interpreted differently should prompt a review of other potentially affected entries. Evaluate the next steps before applicable correction or protest deadlines pass.

• Electronic storage is not the same as verified access. Check that the supporting documents are actually present and retrievable. Ashley also recommends including DDP shipments in the review.

• Give every issue an owner. Start with Ashley’s three-column tracker: entry number, issue, owner. Delegate the work, communicate when it is needed, and follow up rather than assuming the handoff resolved the problem.

• Global Training Center

• Ashley Arnold — LinkedIn

• Ashley Arnold — Global Training Center Instructor Profile

• CBP — ACE Reports

• Additional Background: CBP’s Supply-Chain Visibility Request for Comments

Follow Simply Trade for updates on companion resources and the 90 Days Until 2027 playbook.

This episode provides general educational information. Confirm the requirements and deadlines applicable to your entries before taking corrective action.

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Host: Cindy Allen

What happens when customs practices that once escaped close scrutiny become the focus of enforcement? In this episode of Simply Trade—Cindy’s Version, Cindy Allen turns to Taylor Swift’s “Karma” to explore a message importers, customs brokers, and freight forwarders cannot afford to overlook: compliance risk has a history.

Cindy connects the week’s tariff, court, and agency developments with a practical concern for trade teams—being ready to support their claims when questions arise, not just when the paperwork is normally finalized. She describes reports of shipments being stopped at the northern and southern borders for detailed valuation, origin, and trade agreement documentation, putting added pressure on release processes and after-hours coordination.

The discussion also considers what an Office of Foreign Assets Control (OFAC) settlement involving a freight forwarder can teach the industry about screening controls, and why reviewing today’s transactions is only part of the job. Historical import patterns, undervaluation, misclassification, and transshipment all feature in Cindy’s assessment of a more demanding enforcement environment.

This episode challenges listeners to look beyond routine filings and ask a bigger question: can your organization explain and support its trade decisions—past and present—when scrutiny arrives?

• White House developments: Cindy discusses possible Section 232 tariffs on wind turbines and parts, along with the administration’s approach to Russian oil and gas imports and the objections surrounding it.

• Tariff refund oversight: Cindy reviews lawmakers’ request for a Government Accountability Office (GAO) examination of IEEPA duty refunds, including refund accuracy, recipients, and whether money reached downstream consumers.

• Court challenges and refund access: The episode covers the Section 301 forced-labor case, the Section 338 tariff challenge involving Canada, and expanded CAPE 3 eligibility for additional Court of International Trade filings.

• Implementation and screening: Cindy discusses the entry type 13 deadline extension for mail importations and an OFAC settlement involving a freight forwarder’s sanctions-screening controls.

Cindy’s central theme is customs karma: practices that may previously have been tolerated or overlooked are drawing closer attention in what she describes as a “zero trust” enforcement environment.

She explains why detailed documentation requests at the point of release can disrupt shipments when supporting records are normally assembled or shared later. Her emphasis is on documentation readiness, coordination with customs brokers, and understanding risks in both current transactions and historical import activity.

The discussion connects sanctions screening, undervaluation, misclassification, and transshipment to that broader enforcement focus. Cindy encourages listeners to review their policies and procedures, share examples of disruptive border holds through trade associations, and participate in enforcement-related rulemaking.

• Be ready to support your entry claims. Prepare accessible documentation for valuation, country of origin, free trade agreement qualification, and antidumping duty disclaimers.

• Review the past alongside the present. Cindy stresses that historical import patterns—not just current shipments—can become part of enforcement scrutiny.

• Look beyond a completed screening check. Review the policies, procedures, and screening frequency behind your technology.

• Coordinate before a shipment is stopped. Discuss document access and potential release-time questions with your customs broker, and share examples of problematic border holds through relevant trade associations.

• Global Training Center

• Cindy Allen on LinkedIn

• “Karma” by Taylor Swift — the inspiration for this episode’s trade theme.

• Trade Force Multiplier — Cindy’s company, mentioned as a resource for reviewing trade compliance risks.

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Host: Lalo Solorzano and Andy Shiles

Being good at trade compliance and being known for that expertise are not the same thing. In this episode of Simply Trade, Lalo Solorzano and Andy Shiles welcome Kyle Grobler for a candid conversation about personal branding, professional visibility, and showing up—even when posting feels uncomfortable.

Kyle explains why he committed to sharing his experience on LinkedIn for six months, with one simple goal: help one other person. What followed included new connections, speaking opportunities, and offers for jobs he never applied for. But this is not a conversation about chasing viral posts. It is about making your knowledge useful to others and building relationships through consistent contribution.

The discussion moves from practical profile improvements and meaningful engagement to the human side of professional credibility: admitting mistakes, telling relatable stories, and letting people see the person behind the job title. Lalo shares his own discomfort with being visible, while Andy connects the conversation to sincere leadership and learning from frontline employees.

For trade, customs, and logistics professionals wondering whether they have anything worth sharing, this episode offers a different starting point: your everyday experience may be exactly what someone else needs. You do not have to wait until you feel ready—or until the new year—to begin.

Kyle’s central message is that a personal brand grows through contribution, not just self-promotion. He discusses building a LinkedIn profile that explains the problems you solve, sharing lessons from your work, and engaging thoughtfully with other people’s content.

The conversation also goes beyond social media. Lalo and Andy explore how professional visibility connects to workplace credibility, communicating trade’s value, and building relationships with colleagues at every level. From acknowledging mistakes to listening to frontline employees, the emphasis stays on consistency, sincerity, and community—not perfection or popularity.

• Make your expertise easy to understand. Use your LinkedIn photo, banner, headline, and About section to communicate who you help, the problems you solve, and what you have accomplished.

• Share the lesson, not just the success. Experiences, mistakes, and what you learned along the way can offer another trade professional a useful starting point.

• Contribute more than you ask for. Thoughtful comments, meaningful responses, and genuine conversations build relationships beyond your own posts.

• Choose consistency over perfection. Keep showing up even when engagement is modest. Kyle’s focus is helping someone—not measuring every post against viral numbers.

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Host: Lori Mullins

What happens when a trade policy decision reaches the people responsible for making it work? In this special Simply Trade collaboration with the National Customs Brokers and Freight Forwarders Association of America (NCBFAA), host Lori Mullins sits down with Legislative Committee Chair Leah Ellis and Co-Chair Dave Corn to connect the daily realities of trade with the conversations taking place on Capitol Hill.

Coming out of NCBFAA’s 2026 Government Affairs Conference, Leah and Dave explain why advocacy is a year-round effort—and why firsthand experience matters when lawmakers are weighing changes. The discussion explores the push for more advance notice before tariff changes, the downstream effects on drawback and the broader duty life cycle, and the challenge of strengthening customs enforcement without making legitimate trade harder to facilitate.

At the center of the conversation is a practical question: Who is best positioned to explain what happens at the entry desk, inside a brokerage operation, or when an importer faces an unexpected change?

Leah and Dave make the case that you do not need a government affairs title to contribute. You need real examples, a willingness to speak up, and the commitment to keep the conversation going after the meeting ends.

This episode goes behind the scenes of NCBFAA’s legislative advocacy, showing how members’ operational experiences help inform the association’s conversations with lawmakers.

Lori, Leah, and Dave discuss NCBFAA’s request for at least 30 days’ advance notice of tariff changes, the importance of considering the entire duty life cycle, and the balance between customs enforcement and trade facilitation. Their enforcement discussion includes a verified importer-of-record registry and the position that CBP should determine importer eligibility using government information unavailable to brokers.

They also explain what happens after the Capitol Hill meetings: sharing concrete examples, answering staffers’ questions, maintaining local relationships, and following up throughout the year.

• Tariff notice is an operational issue. NCBFAA’s request for at least 30 days of advance notice is about giving brokers, importers, software providers, and CBP time to prepare for implementation.

• The duty life cycle does not end at entry. Dave explains why drawback, corrections, reconciliation, refunds, and recordkeeping need a place in tariff-policy conversations.

• Effective enforcement needs clear responsibilities. The guests support appropriate broker due diligence while arguing that CBP should determine importer eligibility using information brokers cannot access.

• Advocacy requires participation and persistence. Bring real-world examples, get involved through committees and local associations, and follow up with congressional offices after the conference.

• Global Training Center

• NCBFAA Legislative Committee and Committee Directory NCBFAA

• How to Get Involved in an NCBFAA Committee NCBFAA

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Host: Lalo Solorzano

You checked your customer’s name against a restricted-party list. But do you know who owns that company?

In Episode 3 of 90 Days Until 2027, Lalo Solorzano welcomes Josh Rodman of Schulz Trade Law to discuss the BIS affiliates rule and what exporters can do to prepare. Recorded while the rule was suspended, the conversation looks beyond the name on the invoice to ownership structures, potential licensing requirements, and risks that can exist even when a subsidiary is legally separate from its parent.

Josh brings the issue to life through a client’s proposed sale of approximately $250,000 in electrical power equipment to a Chinese-owned subsidiary in Jamaica. The example leads to a critical question: what happens when a deal is signed before a rule takes effect, but the goods ship afterward?

Lalo and Josh also explore the limitations of relying on screening tools alone, the importance of understanding different restricted-party lists, and why uncertainty about implementation is not a reason to postpone preparation.

This week’s tip is to start investigating the ownership of your overseas counterparties now. Understanding those relationships can help your team identify questions that need attention before a transaction reaches the shipping stage.

Knowing your customer’s name is not the same as understanding its ownership.

Josh explains how the BIS affiliates rule would extend restrictions to certain unlisted companies based on ownership of 50% or more, including aggregated ownership. His Jamaica example illustrates why a subsidiary’s separate legal identity and location do not answer every export-compliance question.

The discussion also covers export timing, the uncertainty surrounding any future temporary general license, and the possibility that a subsidiary could serve as a route for goods to reach a restricted parent. Josh recommends investigating ownership now and reviewing the distinctions among the Entity List, Military End-User List, and SDN List.

Rule-status clarification — checked October 20, 2026: The published BIS suspension notice runs through November 9, 2026, with reinstatement scheduled for November 10, 2026, absent further action. The possible extension discussed in the recording should not be treated as an announced change. Check for subsequent BIS updates before relying on these dates. Federal Register

Scope clarification: The episode refers broadly to the SDN List. For the BIS affiliates rule specifically, the published text identifies SDN designations under the programs listed in EAR § 744.8(a)(1), rather than every SDN designation. Federal Register

• Look beyond the customer’s name. Josh recommends examining ownership layers and percentages—not assuming a name-only screening result resolves the affiliates-rule question.

• Signing a contract does not settle export eligibility. Josh explains why the date of export matters and why any applicable temporary general license would need to be evaluated separately.

• A suspended rule does not eliminate other risks. The conversation highlights diversion concerns when an otherwise separate subsidiary could help an Entity List parent obtain goods.

• Understand what each list actually restricts. Josh encourages exporters to review the Entity List, Military End-User List, and SDN List rather than treating them as interchangeable—or assuming every listing prohibits every kind of business.

• Global Training Center

• Josh Rodman — LinkedIn

• Josh Rodman — Schulz Trade Law

• BIS Affiliates Rule — Published Rule and Scope

• BIS — One-Year Suspension of the Affiliates Rule

• OFAC — 50 Percent Rule FAQs

Follow Simply Trade for updates on companion resources and the planned 90 Days Until 2027 playbook.

This episode provides general educational information and is not legal advice. Verify the requirements applicable to your transaction.

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Host: Pete Mento and Cindy Allen

Recorded live at VMA26 in Norfolk, Pete Mento and Cindy Allen bring the Pete and Cindy Show to the conference stage for a candid, no-spin conversation about tariffs, refunds, enforcement, and what importers should do next. They unpack Sections 301, 232, 122, and 338 as tools of leverage, revenue, national security, and industrial policy—and question whether the current tariff strategy is producing the promised reshoring results. VMA26 brought shipping, port, logistics, and trade leaders together under the theme “Anchored: Grounded in Strategy. Ready for What’s Next.” Va Maritime

The discussion turns practical as Pete and Cindy examine IEEPA refunds following the Supreme Court’s 2026 ruling, ACH setup, liquidation risk, and the need to involve trade counsel before money is left on the table. Then comes the warning: CBP, DOJ, BIS, and other agencies are using better data, deeper supply-chain visibility, and faster analytics in an increasingly enforcement-first environment. Supreme Court

They also explore CBP’s advanced-data proposals, including foreign export documentation and supplier information that could reshape procurement, contracts, forwarding, and entry processes. Their advice is direct: engage suppliers now, strengthen cooperation clauses, evaluate service providers for compliance—not just price—and invest in people, systems, and lawful duty-mitigation tools. The line that captures the entire session: hope is not a strategy. Federal Register

• The IEEPA tariff ruling and the ongoing duty-refund process

This live discussion connects tariff policy directly to operational execution. Pete and Cindy argue that tariffs, refunds, data collection, supply-chain relationships, and enforcement can no longer be managed as separate issues.

Tariffs as leverage

The hosts examine how different tariff authorities are being used to influence negotiations, protect strategic industries, raise revenue, encourage domestic production, and reshape trade relationships with China, Canada, Mexico, and other partners.

Refunds and lawful mitigation

Pete and Cindy discuss the IEEPA refund process and the importance of reviewing affected entries, ACH information, liquidation status, and available legal options. They also highlight drawback, first sale, reconciliation, and foreign-trade zones as strategies companies should evaluate with qualified advisers.

Enforcement powered by data

The conversation explores how ACE data, supply-chain mapping, anomaly detection, and interagency coordination are increasing the government’s ability to identify discrepancies. The hosts warn that companies should expect faster, more targeted enforcement across both imports and exports.

Advanced data and shared responsibility

CBP’s ANPRM raises questions about foreign export declarations, invoices, classifications, values, certificates of origin, business identifiers, and earlier filing. Pete and Cindy explain why these proposals could affect procurement, supplier contracts, freight forwarding, carrier operations, and customs entry processes—not only the trade compliance department. The public comment period ends December 1, 2026. Federal Register

• Hope is not a strategy. Importers should model tariff exposure, prepare for continued enforcement, and build plans that do not depend on duties simply disappearing.

• Review potentially eligible IEEPA entries, confirm ACH refund information, monitor liquidation status, and involve trade counsel when administrative or judicial action may be necessary.

• Begin supplier outreach now. Determine who holds foreign export records, add government-cooperation and data-sharing language to contracts, and consider commenting on CBP’s ANPRM before December 1, 2026.

• Evaluate brokers, forwarders, and carriers for their compliance programs, escalation procedures, recordkeeping, and willingness to challenge questionable instructions—not solely their rates and service levels. The importer of record remains ultimately responsible.

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