From AFOA General Counsel, Olsson Frank Weeda:

Here are two client memoranda addressing recent developments and practical steps importers can take to preserve their rights to duty refunds. This memorandum summarizes recent activity at the Court of International Trade, and this one outlines key considerations for CBP’s Automated Commercial Environment (ACE), including ACE account setup, ACH enrollment, and core reporting requirements.

Please note that we are continuing to actively file refund actions at the CIT and to protest entries for clients who have chosen to move forward now rather than wait for full implementation of CAPE (CBP’s proposed ACE-based refund functionality). We are also available to provide ACE training and troubleshooting support as needed.

We will continue to monitor this situation closely and will report all significant developments to you. In the interim, please do not hesitate to reach out to us with questions or requests for additional information.