Simply Trade

[Cindy's Version] The Story of Us: Tariff Changes, CAPE Confusion, and Waiting for Answers

Host: Cindy AllenShow: Simply Trade – Cindy’s VersionPublished: April 9, 2026Length: ~16 minutesPresented by: Global Training Center
The Story of Us: Tariff Changes, CAPE Confusion, and the Trade Community Waiting for Answers
Cindy Allen returns with a wide-ranging trade update set to Taylor Swift’s “The Story of Us,” using the song’s theme of miscommunication to frame the current disconnect between CBP, the courts, and the trade community. From a new DHS funding update and fresh uncertainty around tariffs and valuation to the evolving CAPE refund process and the latest questions around customs business, this episode captures a moment where the trade world is working hard to keep up with fast-moving policy changes.
What You’ll Learn in This Episode
DHS and trade funding
DHS remains largely unfunded, although TSA funding has now passed and some CBP officers remain funded under prior legislation.
Many trade-related staff are still working without pay, and the shutdown pressure has now stretched beyond a month.
Last sale and valuation debate
Congress is still considering the last sale bill, which could eliminate last sale as a valuation method.
Cindy explains that last sale has long been treated as part of the broader transaction value framework and is supported by court history, but Congress can still change the law if it chooses.
White House tariff threats
The White House floated 50% duties on countries that sell weapons to Iran, though Cindy questions what legal authority could support that now that IEEPA has been ruled unlawful.
For China, the government could potentially revise Section 301 tariffs, but for other countries, the implementation path is unclear.
Forced labor enforcement
The Labor Department announced a new tool for assessing foreign forced labor practices, but details were sparse.
Cindy notes that CBP already has a strong forced labor framework and suggests the Labor Department may be stepping into a larger detection/enforcement role.
WTO criticism from USTR
U.S. Trade Representative Jameson Greer published an op-ed criticizing the World Trade Organization, signaling frustration with its current effectiveness and casting doubt on the U.S. role going forward.
Cindy highlights this as another sign that global trade institutions may be under pressure to prove relevance.
232 updates now in effect
The recent steel and aluminum 232 changes took effect on April 6.
Cindy notes that the system seems to be running smoothly, with de minimis treatment for some shipments under 15%, reduced or removed tariff coverage for certain HDS annex items, and new component-level classifications that reduce ambiguity even if the tariff burden remains high.
CBP also released guidance on April 3, which importers subject to 232 should review carefully.
USMCA remains strained
USMCA negotiations continue, but Cindy says they are tense and may not conclude by the July 1 deadline.
Despite frustration and mixed positions among the three governments, she notes the agreement still matters for North American production and U.S. manufacturing support.
Customs business ruling and trade tech
A recent customs business ruling has created concern among AI and trade tech companies, especially around whether certain activities now require a licensed customs broker.
Cindy explains that the issue muddies the water for brokers, tech providers, and importers alike and will likely require clarification from CBP.
ACE portal account requirement
CBP has rolled out a new ACE portal account application process.
Importers seeking refunds now need an ACE Portal account, and Cindy recommends checking CBP’s site or speaking with a broker to understand the new application process.
Strait of Hormuz and market impact
The war with Iran is paused for two weeks, but a reported $2 million vessel toll for safe passage through the Strait of Hormuz is raising alarms.
Cindy also points to Bloomberg reporting that some Asian factories are seeing 55% price increases on plastics, showing how oil transit issues ripple into fertilizers, plastics, diesel, and broader market volatility.
CAPE and “The Story of Us”
Cindy says she chose “The Story of Us” because the song reflects the miscommunication and silence she sees between CBP, the courts, and the trade community. The CAPE process is still being built, and while CBP has filed detailed updates with the court, the real uncertainty is how the court will interpret those filings and what rules will ultimately apply to importers.
The biggest unresolved questions remain whether finally liquidated entries will be included, whether protests or court actions will be required, and how refund filings will ultimately work. Cindy notes that the lead case changed from Artemis to a new test case after Artemis withdrew, meaning the court started over with new orders and the process remains in motion.
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What Importers Tend to Get Wrong About Importing

Importing isn’t as simple as buying a product overseas and having it show up at your door.
In this episode of Simply Trade, Lalo Solorzano and Andy Shiles break down three of the most common (and costly) assumptions business owners make about importing—and how those mistakes can quietly erode margins, create compliance risk, and lead to serious problems with U.S. Customs.
If you’re importing—or thinking about it—this is a must-listen.
📌 What You’ll Learn
Why your supplier is not responsible for your compliance
How duty rates have shifted from predictable to volatile
The real role of a customs broker (and what they don’t own)
Why bad data = compliant filings… that are still wrong
How small mistakes can turn into costly enforcement issues
🔑 Key Takeaways
1. Your Supplier Does NOT Handle Everything
Many importers assume their overseas supplier manages the process.
Reality:
The supplier’s priority is getting paid
You are the Importer of Record
You are accountable to U.S. Customs and Border Protection
If documentation is wrong—valuation, country of origin, product description—you own the consequences.
“Your supplier may ship the goods—but you own the risk.”
2. Duties Are No Longer Predictable
What used to be a stable, forecastable cost is now a moving target.
Tariffs and trade policies change rapidly
Sourcing decisions directly impact duty exposure
Long purchasing cycles increase risk
“Duty used to be a line item. Now it’s a variable you have to actively manage.”
3. Compliance Is NOT Your Broker’s Job
Hiring a broker does not transfer liability.
Brokers file based on the data you provide
They facilitate compliance—but don’t own it
Incorrect data = correctly filed… but still wrong
“Customs holds the importer accountable—not the broker.”
⚠️ Real-World Risk
Even when no one is trying to cut corners:
Miscommunication with suppliers
Last-minute product changes
Incorrect documentation
…can result in:
Shipment delays
Exams or holds
Seizures
Long-term compliance issues
🧠 The Bigger Insight
All three mistakes come down to one thing:
👉 Misunderstanding responsibility
Importing is not passive.
The companies that succeed:
Maintain internal oversight
Understand classification and documentation
Treat trade as a controlled process—not a transaction
🎯 Who This Episode Is For
Business owners importing goods
E-commerce sellers sourcing overseas
Small to mid-size importers
Anyone new to international trade
📣 Mentioned in This Episode
National Customs Brokers & Forwarders Association of America (NCBFAA Conference)
U.S. Customs and Border Protection
Credits
Hosts:
Lalo Solorzano
Andy Shiles
Produced by: Global Training Center
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[TIPS] From Tactical to Strategic: How to Build a Mature Trade Organization

Hosts
Renee Chiuchiarelli
Julie Parks
Published
April 2026
Episode Length
~10 minutes
🎯 Episode Summary
In this episode of Simply Trade Tips: Hammer & Heels, Renee and Julie continue their Tactical vs. Strategic series by focusing on the how.
If the last episode defined the difference…this one answers the real question:
👉 How do you actually build a more strategic, mature trade organization?
From stabilizing operations to introducing KPIs and redefining roles, this episode lays out a practical roadmap for evolving beyond reactive, tactical work into a proactive, value-driving function.
🔑 Key Takeaways
1. Start with a Clear End-State Vision
Before making changes, define:
Your problem statement (e.g., too much manual work, rework, delays)
Your future state (automation, efficiency, reduced firefighting)
👉 Clarity drives alignment.
2. Stabilize Your Operations First
You can’t build strategy on chaos.
Focus on:
Clean master data
Classification governance
Standard broker instructions
Documented SOPs (and keep them updated!)
Controls to prevent repeat errors
3. Eliminate Manual Work (Quick Wins Matter)
Look for opportunities to:
Automate screening and validation checks
Replace email approvals with system controls
Implement exception-based workflows
💡 Small wins create momentum—and buy-in.
4. Define Roles with a RACI Framework
Separate tactical vs. strategic responsibilities:
Shift transactional work to:
Brokers
Shared services
Create roles focused on:
Analytics
Optimization
Strategy
👉 Not everything belongs in trade. Know your boundaries.
5. Introduce Metrics That Show Value
Move beyond activity tracking to impact measurement:
Duty savings & cost avoidance
Free Trade Agreement utilization (e.g., USMCA)
Error rate reduction (first-time accuracy)
Cycle time improvements
Audit readiness / risk metrics
📊 Measure over time—this is where transformation becomes visible.
6. Think Like a Strategic Leader
Strategic trade leaders:
Remove roadblocks
Translate regulations into business decisions
Speak in financial and operational impact
Influence sourcing and supply chain early
Build dashboards (not just spreadsheets)
Design compliance into systems
👉 This is where trade becomes a business driver—not just a function.
7. Use Quick Wins to Drive Change
Examples:
Eliminate recurring manual tasks
Reassign non-trade work (like track & trace)
Implement broker scorecards
Pilot automation or controls
🎉 And don’t forget to celebrate progress.
💡 FIO (Figure It Out) – This Week’s Challenge
Take a step back and assess your organization:
List the tasks your team performs
Survey how much time is spent on each
Identify:
% of time spent on tactical vs. strategic work
Time spent during shipment vs. pre/post (the “bookends”)
👉 This exercise will reveal your true maturity level—and where to focus next.
💬 Join the Conversation
How much of your team’s time is spent firefighting vs. driving strategy?
Have you tried a time study or implemented KPIs that changed your organization?
👉 Join the discussion in the Trade Geeks Community and share your FIO!
Credits
Hosts:Renee Chiuchiarellihttps://www.linkedin.com/in/renee-chiuchiarelli-lcb-ccs-8964a19/?utm_source=SimplyTradePodcast
Julie Parkshttps://www.linkedin.com/in/julie-ann-parks/?utm_source=SimplyTradePodcast
Producer:Lalo Solorzanohttps://www.linkedin.com/in/lalosolorzano/?utm_source=SimplyTradePodcast
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Presented by:Global Training Center — education, consulting, workshops & compliance resources for trade professionals.👉 https://www.globaltrainingcenter.com/?utm_source=SimplyTradePodcast
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[ICPA] What ICPA Delivers: Connections, Career Boosts, and AI Insights with Benita Lee

Host: Annik SobingGuest: Benita Lee, Certified Customs Specialist (U.S. and Canada)Published: April 2026Length: ~20 minutesPresented by: Global Training Center
ICPA After the Conference: Building Community, Sharing Ideas, and Preparing for What’s Next
In this post-ICPA conversation, Annik sits down with Benita Lee, an independent consultant and trade compliance strategist, to reflect on the energy, diversity, and value of the ICPA San Antonio conference and why this community continues to matter for trade professionals across import, export, supply chain, and government relations. Together, they talk about how the conference brings together practitioners, legal experts, tech leaders, students, and even investors to share real-world perspectives on tariffs, refunds, AI, and the changing trade landscape.
What You’ll Learn in This Episode
Why ICPA matters
ICPA is more than a conference—it’s a place where trade professionals connect, learn, and build a stronger community.
Benita and Annik talk about how the event helps break the isolation many people feel in customs and compliance roles.
The San Antonio conference experience
This year’s conference was described as the largest and most diverse yet, with strong attendance, active booth traffic, and meaningful conversation across tracks.
Attendees included legal counsel, compliance professionals, Big Four alumni, tech-minded practitioners, and newer voices entering the industry.
AI and practical use cases
A key conference theme was AI in trade compliance, with sessions focused on practical use cases instead of fear-based “replacement” talk.
Benita highlights the value of these sessions in showing how AI can support existing work, not eliminate the need for expertise.
Student engagement and career development
The conference welcomed students and scholarship recipients, reinforcing ICPA’s role in helping the next generation find mentors and learn the trade path.
Benita points to sessions like “Advancing Your Career” with Laila Landis as must-see content for both students and experienced professionals.
Canada conference perspective
The upcoming ICPA Canada conference in June is a different lens on trade, especially given Canada’s export relationship with the U.S. and the current political tension.
Benita explains why Canadian practitioners benefit from seeing both the U.S. and Canadian sides of the trade equation and how ICPA helps keep the conversation practical rather than political.
Connections and collaboration
A recurring theme of the episode is that trade is solved through connections—meeting the right people, asking questions, and finding the experts who can help.
Benita emphasizes that ICPA makes it easy to engage, network, and find mentors, which can dramatically shorten the learning curve in your career.
Upcoming ICPA Events Mentioned
ICPA Canada: June 7–9, 2026.
ICPA Dresden: April 8–10, 2026.
ICPA Grapevine, Texas: September 13–15, 2026
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Join the Trade Geeks Community
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[Cindy's Version] Begin Again: Refunds are coming, but so are 100% Tariffs

Host: Cindy AllenPublished: April 3, 2026Length: ~15 minutesPresented by: Global Training Center
Summary
In this week’s episode of Simply Trade: Cindy’s Version, Cindy Allen breaks down a major shift in trade operations as CBP moves closer to launching the CAPE system for IEEPA duty refunds—while at the same time, new Section 232 actions signal that trade enforcement is far from slowing down.
CBP has indicated it is on track for an April 20 rollout of CAPE, with key components nearing completion. However, Phase 1 will only cover certain entries, leaving many importers navigating critical decisions around protests and timing.
At the same time, new developments in pharmaceutical tariffs and steel and aluminum revisions suggest that, despite recent legal challenges, trade enforcement is evolving—not retreating.
Inspired by Taylor Swift’s Begin Again, Cindy walks through why this moment feels less like closure—and more like the start of a new phase in global trade compliance.
This Week in Trade
• CBP signals April 20 target for CAPE rollout tied to IEEPA refunds • Phase 1 expected to cover ~63% of entries, excluding many already liquidated cases • Judge highlights importers’ right to file protests, raising strategic considerations • Strait of Hormuz disruptions continue to create supply chain uncertainty • No movement on key legislation including First Sale and Foreign Importer of Record rules
IEEPA Refunds & CAPE: Where Things Stand
CBP continues to make progress toward launching CAPE (Consolidated Administration and Processing of Entries):
• Claim portal (~85% complete)• Mass processing of entries (~60% complete)• Review and liquidation (~80% complete)• Refund processing (~75% complete)
Phase 1 will:• Focus on unliquidated entries and those within voluntary reliquidation windows• Exclude fully liquidated entries, protests, drawback, and certain AD/CVD cases
⏱️ Timeline:• Target launch: ~April 20• Estimated processing: up to 45 days post-launch
Section 232: We’re “Beginning Again”
This week brought significant new developments under Section 232:
Pharmaceutical Tariffs
• 100% duty on name-brand pharmaceuticals• Generics excluded• Implementation expected within 180 days
Key complexity:• Importers must now identify brand vs. generic at entry• Multiple exemptions and reduced rates tied to reshoring and trade agreements
Steel & Aluminum Updates
• 50% duty remains for core steel/aluminum products• 25% duty on derivative products (full value)• New de minimis exemption for products with <15% steel/aluminum by weight
These updates simplify some calculations—but may increase duty exposure for many importers.
Key Takeaways
• CAPE is progressing—but refunds will be phased and complex• Importers should evaluate protest strategies carefully• Trade enforcement is not slowing—it’s resetting and expanding• Section 232 is entering a new operational phase• Compliance will require more detailed product-level data than ever before
Resources & Mentions
• Global Training Center• Trade Force Multiplier
Credits
Host:• Cindy Allen – LinkedIn• Trade Force Multiplier
Producer:• Lalo Solorzano – LinkedIn
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[Canada] – Navigating Supply Chain Disruption, Infrastructure Shifts, and Trade Uncertainty

Host: Warrington EllacottGuest: David A. JohnstonPublished: April 1, 2026Length: ~20 minutesPresented by: Global Training Center
🌍 Adapting to Disruption in a Shifting Trade Landscape
In this episode of Simply Trade [Canada], Warrington Ellacott sits down with Dr. David A. Johnston to explore how geopolitical shifts, infrastructure investments, and evolving trade dynamics are reshaping supply chains.
From Canada’s renewed focus on nation-building infrastructure to the ongoing uncertainty surrounding USMCA negotiations, this conversation highlights the realities businesses face today—and the strategies they need to stay resilient. Dr. Johnston shares insights from his work at the Schulich School of Business, emphasizing the importance of flexibility, collaboration, and long-term planning in an increasingly volatile global trade environment.
🧠 What You’ll Learn in This Episode:
🌐 How geopolitical risks and policy shifts are disrupting global supply chains🏗️ What Canada’s major infrastructure investments mean for importers and exporters🤝 Why communication with supply chain partners is critical during uncertainty📦 How to think about transportation flexibility, including shifting modes like air, rail, and ocean📊 Practical ways to manage short-term risk while planning for long-term change🌎 Why diversification and global market expansion require new logistics strategies
🔑 Key Takeaways:
Strong communication with suppliers, carriers, and partners is essential during disruption.
Infrastructure investments create long-term opportunities—but won’t solve short-term challenges.
Flexibility in transportation modes can keep goods moving, even at higher costs.
Businesses should balance immediate risk management with longer-term strategic repositioning.
Trade relationships—especially between Canada and the U.S.—remain critical despite uncertainty.
Disruption often creates opportunity, particularly in emerging sectors like infrastructure and defense.
📌 Resources & Mentions:
George Weston Ltd Centre for Sustainable Supply Chains – Schulich School of Business
Master of Supply Chain Management Program – York University
Sloan Management Review (2022) – Preparing for Supply Chain Disruptions
USMCA / CUSMA Trade Agreement
CPTPP (Comprehensive and Progressive Agreement for Trans-Pacific Partnership)
🎧 Credits
Host:
Warrington Ellacott – https://www.linkedin.com/in/warringtonellacott/
Guest:
David A. Johnston – https://www.schulich.yorku.ca/faculty-research/george-weston
Producer:
Lalo Solorzano
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Presented by: Global Training Center — providing education, consulting, workshops, and compliance resources for trade professionals.👉 https://www.globaltrainingcenter.com
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[TIPS] From Firefighting to Forward Thinking: Shifting Trade from Tactical to Strategic

Hosts: Renee Chiuchiarelli & Julie Parks
Published: March 31, 2026
Length: ~10 minutes
Presented by: Global Training Center
🎧 Episode Summary
In this episode, Renee and Julie kick off a new series focused on a critical evolution in global trade:
👉 How do you shift your team from tactical execution to strategic impact?
Most trade teams are buried in transactions—processing entries, fixing data, responding to audits. But today’s environment demands more.
The question is no longer:“Are we processing trade?”
It’s:“Are we leading it?”
This episode breaks down the difference between tactical vs. strategic work, why teams get stuck, and what’s at risk if you don’t evolve.
🔑 Key Takeaways
1. Tactical Work = Necessary, But Reactive
Tactical work keeps the business moving—but it’s often:
Transaction-focused
Time-sensitive
Manual and repetitive
Reactive and firefighting
Examples include:
Entry processing
Data corrections
Broker email back-and-forth
Audit scrambling
Manual screening and rework
👉 It’s essential—but it won’t move your organization forward.
2. Strategic Work = Value Creation
Strategic trade work is where real impact happens.
It includes:
Tariff mitigation strategies
Country of origin and sourcing optimization
Trade analytics and risk pattern identification
Broker governance and performance management
Automation and control design
Characteristics of strategic teams:✔ Proactive✔ Data-driven✔ Cross-functional✔ Focused on financial and operational outcomes
3. Today’s Reality: You Need Both
This isn’t an either/or conversation anymore.
👉 The current trade environment demands:
Tactical excellence and
Strategic leadership
As Renee highlights, even seasoned leaders are being pulled back into the details—while tactical teams are being asked to think more strategically.
4. Why Teams Get Stuck in Tactical Mode
Common reasons include:
Understaffing
Constant operational pressure
Poor data quality
Lack of documented processes
Over-reliance on email and tribal knowledge
Leadership viewing trade as purely transactional
No KPIs tied to value creation
5. The Risk of Staying Tactical
If your team never evolves:
Errors repeat and expand during audits
Duty savings opportunities are missed
Regulatory changes outpace your response
Burnout and turnover increase
Trade gets excluded from strategic planning
👉 You become a cost center… instead of a strategic partner.
🚀 Figure It Out (FIO) – This Week’s Action
Before you can evolve, you need visibility.
👉 Track where your team is spending time.
List out current activities and projects
Categorize them:
Tactical
Strategic
Identify where the majority of time is going
🎯 This becomes your baseline for the rest of the series.
💬 Join the Conversation
Where does your team spend most of its time today?
🔥 Firefighting?
📊 Strategy?
⚖️ A mix of both?
👉 Head over to the Trade Geeks community and share your breakdown—and let’s compare notes.
Credits
Hosts:Renee ChiuchiarelliJulie Parks
Producer:Lalo Solorzano
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Presented by:Global Training Center — education, consulting, workshops & compliance resources for trade professionals
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Simply Trade Podcast on LinkedIn
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Trade Geeks Community
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[ROUNDUP] Long-Term Thinking in a Short-Term World: A CEO’s View on Growth and Culture with Chris Bachinski

Host: Annik SobingGuest: Chris Bachinnski, Co‑CEO & President, GHY InternationalPublished: March 2026Length: ~35 minutesPresented by: Global Training Center
Annik sits down with Chris Bachinnski, Co‑CEO and President of GHY International, for a leadership‑focused conversation on what it really takes to build and sustain a customs brokerage and trade business in a volatile, tech‑driven environment. Starting from sweeping floors in his dad’s trucking company at age 12 to leading a 100+ year‑old firm, Chris shares how work ethic, curiosity, and culture have shaped his career across transportation, marketing, and now trade.
What You’ll Learn in This Episode
Chris’s unconventional path to trade
Grew up in trucking, bought his dad’s company in his 20s, then sold into a publicly traded roll‑up and learned the pros/cons of “quarterly mindset.”
Shifted into a small marketing agency as CFO/COO, where he discovered the tight link between brand and culture and began doing leadership/culture training for clients.
GHY first hired his firm for branding and leadership work; later, owner Rick Reeseinvited him in as President specifically for his leadership and culture skills, not customs expertise.
Designing and changing culture on purpose
Chris interviewed all 105 GHY associates in his first 6–7 months just to listen, then worked with leadership to define: what must never change, what needs to improve, and which behaviors will be tolerated.
His core belief: “Culture is the result of the behaviors you permit”—leaders must live values first, then hold people accountable, even when that means making hard calls on long‑tenured but misaligned employees.
From operator to enterprise‑level leader
With GHY now ~245–250 people, Chris’s CEO coach pushed him to stop being involved in everything and focus on: looking around the corner, aligning the organization, and holding leaders accountable.
He still stays grounded by walking the office daily, restarting one‑on‑one interviews with staff after 10 years, and sharing results from his annual leadership feedback survey with the entire company.
Leading through uncertainty and mistakes
In COVID and the recent tariff/trade waves, GHY leaned into two non‑negotiables: care for people and care for clients, avoiding knee‑jerk layoffs and thinking long‑term even after a “spooked” decision in early 2025.
On errors, Chris rejects the “I let people make mistakes so they learn” line as arrogant; instead, he tells the story of a six‑figure error where GHY refused a resignation, treated it as (expensive) education, and moved forward.
Advice for aspiring leaders
Chris distinguishes between title‑driven leaders and those who see leadership as stewardship: taking what’s been entrusted, making it better, and protecting it for the future.
His core advice: cultivate insatiable curiosity, ask lots of questions, seek mentors, practice empathy (especially now, with stressed employees and customers), and avoid short‑term, fear‑based decisions.
Tech, AI, and the future of brokerage
Chris is candid with his board that technology is the one thing he least wants to under‑estimate; the impact he thought was 5–10 years out is arriving much faster.
GHY’s focus: embrace technology plus process improvement not as a headcount weapon, but as a tool to make people better, improve accuracy, and help clients succeed—constantly questioning “we’ve always done it this way.”
CreditsHost: Annik SobingGuest: Chris Bachinnski (Co‑CEO & President, GHY International)Producer: Annik Sobing
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[Cindy's Version] Living Through Section 122, Steel Valuation Confusion, and the IEEPA Refund Wait, Forevermore

Host: Cindy AllenShow: Simply Trade – Cindy’s VersionPublished: March 27, 2026Length: ~13 minutesPresented by: Global Training Center
Evermore: Section 122, Steel/Aluminum Valuation, DHS Funding, and the Never‑Ending IEEPA Refund Saga
Cindy Allen returns with another Taylor Swift–themed trade update, this time using “Evermore” to capture how the trade community feels about the seemingly endless cycle of new tariffs, court decisions, and refund processes. She covers leadership changes at DHS, shifting timelines for key CBP events, fresh confusion around steel and aluminum valuation, Section 122 and 301/232 moves aimed at replacing IEEPA revenue, and why she thinks the trade world needs to hit “pause” on IEEPA expectations until CBP’s CAPE process is truly defined.
What You’ll Learn in This Episode
DHS & CBP updates
New DHS Secretary Markwayne Mullin, a Trump‑aligned former U.S. Representative from Oklahoma, is sworn in; early signals focus on immigration, with little yet on customs.
CBP’s Trade and Cargo Summit in Dallas is postponed from next month to September due to funding issues; existing registrations will be transferred, with updated instructions to come via CSMS/announcements.
USMCA and steel/aluminum valuation
USMCA: U.S. and Mexico are in talks to extend/renew the agreement using three‑year review periods with annual extensions—essentially letting it “limp along” another 4–10 years, but at least keeping parties at the table.
Steel/aluminum/copper components: CBP has issued new but confusing and partly contradictory guidance on valuation; with court challenges pending and no comprehensive methodology, Cindy urges importers to consult counsel and test whether their approach is defensible under reasonable care standards.
Section 122, 301, and 232 moves
The White House again signals raising Section 122 tariffs from 10% to 15%, but provides no timing; the statutory 150‑day clock keeps running, raising questions about whether they’ll increase within that window or let it lapse and start a new 122 action.
Legal uncertainty: Can the administration lawfully let one 122 action expire and immediately launch another at 15%? With no case law on this rarely used tool, Cindy expects eventual court challenges.
New or adjusted Section 301 and potential 232 cases are clearly framed as ways to replace lost IEEPA revenue after the Supreme Court ruling; the administration also hints that announced rates may change after investigations and hearings.
Forced labor and 301 justification questions
One proposed 301 angle targets countries that “don’t fully enforce forced labor protections,” but Cindy questions how foreign import enforcement links to unfair trade practices harming U.S. commerce, given the U.S. already has its own forced labor import rules.
She flags this as another area ripe for challenge if 301 gets stretched to cover other countries’ internal enforcement of their own import regimes.
DHS budget standoff and FMC decision
As of 1 p.m. CT on March 27: No DHS funding bill fully passed; the Senate approved a measure apparently including DHS funding but maybe not CBP/ICE, and then recessed until mid‑April. The House and the President’s final positions remain uncertain.
Strait of Hormuz: Limited, negotiated safe‑passage traffic continues for some countries, but full reopening hasn’t happened; oil over $100/barrel is impacting carriers and downstream users.
FMC: Denies some carriers’ requests for immediate rate hikes tied to Hormuz‑related fuel costs, holding them to the 30‑day notice requirement since the filings didn’t meet the criteria for accelerated increases.
Evermore & IEEPA Refunds: Why Cindy Says “Pause”
Using “Evermore,” Cindy captures the community’s sense that the “pain” of constant change might last forever—but the song’s ending points to eventual relief. She applies that to IEEPA refunds and the developing CAPE process:
What we know (high level)
CBP is building a CAPE‑based, automated, bulk refund system.
Refunds will go to the importer of record or the broker, and complexity may factor into prioritization, as suggested in CBP Executive Director Brandon Lord’s declaration.
What we don’t know (the bigger list)
When refunds actually start flowing.
What data declarations must include (entry number only, entry + IOR, more?).
How liquidation status will drive treatment:
Not liquidated.
Liquidated but within 90 days (CBP’s reliquidation window).
Between 90 and 180 days (inside protest window).
Beyond 180 days (finally liquidated).
Whether courts will effectively override the 180‑day finality to enable refunds on finally liquidated entries, and what administrative mechanism would exist to do so.
How CBP will handle prioritization, multiple brokers on the same importer’s entries, and any limits on bulk submissions.
Whether CBP will accelerate or use the normal ~314‑day liquidation cycle for unliquidated entries tied to IEEPA.
Given the sheer volume of open questions and the flood of webinars, articles, and press coverage, Cindy’s message to importers and brokers is to take a breath, recognize what is actually known, avoid over‑promising internally, and wait for clearer CAPE details rather than reacting to every rumor. Like the end of “Evermore,” she believes this phase of pain will not be forever.
CreditsHost: Cindy AllenProducer: Annik Sobing 
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[CRIMES] Locked In or Locked Out? The Tariff Case That Changed Everything

🎧 Host(s)
Lalo Solorzano
Andy Shiles
🎤 Guest
Mollie Sitkowski – Partner at Faegre Drinker
📅 Published Date
March 26, 2026
⏱️ Episode Length
~36 minutes
🧠 Episode Summary
In this episode of Simply Trade [CRIMES], we dive into a real-world trade case that highlights what can go wrong when compliance breaks down.
Joined by trade attorney Mollie Sitkowski, Lalo and Andy unpack the details behind the case—what happened, where things went sideways, and what trade professionals can learn from it.
From regulatory missteps to enforcement realities, this episode goes beyond theory and into the practical consequences companies face when trade compliance isn’t handled correctly.
If you’ve ever wondered how small decisions can escalate into major legal and financial exposure—this episode is for you.
🔑 Key Learnings
How real trade violations unfold in practice—not just in theory
The role of intent vs. negligence in enforcement actions
Common compliance gaps that can lead to significant penalties
How customs authorities evaluate and pursue cases
What companies should be doing to mitigate risk before issues arise
💡 Key Takeaways
Trade compliance failures often start with small oversights that compound over time
Documentation, classification, and internal controls are critical risk areas
Enforcement is not just about penalties—it’s about accountability and precedent
Having the right expertise (legal + compliance) can change the outcome significantly
Learning from real cases is one of the most effective ways to strengthen your program
⚖️ Case Breakdown
Overview of the case and key facts
What triggered enforcement attention
Where the compliance breakdown occurred
Legal arguments and outcomes
Broader implications for the trade community
🔗 Resources & Mentions
U.S. Court of International Trade (CIT)
Relevant customs regulations and enforcement frameworks
👏 Credits
Hosts: Lalo Solorzano & Andy Shiles
Guest: Mollie Sitkowski
Produced by Global Training Center
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