The Lindsey Graham Act just took effect with 500% tariffs on Russian goods, but I heard they’re waived. Do I need to do anything?

Not immediately, but you should map your exposure now. Executive Order 14436, signed October 16, 2026, implements the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026: a 500% ad valorem duty increase on Russian-origin goods, plus a 100% duty increase on goods from the five largest importers of Russian crude oil and natural gas and the five largest facilitators of Russian sanctions evasion, triggered by new qualifying purchases on or after October 18, 2026. The same order immediately waives all of these increases under a presidential national-interest certification submitted to Congress. Critically, the waiver has no expiration date and no required notice period — it stays in effect only until the President or Secretary of State determines otherwise. If you have any Russian-origin inputs, or customers or suppliers in the handful of countries that are the largest buyers of Russian oil and gas, you are one determination away from a 500% or 100% duty increase with effectively no warning. Build that scenario into your risk register today rather than waiting for a reinstatement notice.

There’s a new lawsuit over Section 338 tariffs on Canadian goods — should I hold off paying duties on my Canadian entries?

No. The duties remain legally owed and payable regardless of the litigation, and failing to pay will not protect you — it will just add penalties. A New Jersey-based food importer filed suit at the Court of International Trade on October 20, 2026, challenging the legality of tariffs imposed on Canadian merchandise under Section 338 of the Tariff Act of 1930, the same statutory mechanism underlying the up-to-50% bilateral tariffs that have been in place on more than $20 billion of Canada-U.S. trade since the August breakdown of a near-finished Canada tariff deal. What you should do is preserve your own rights: keep complete entry documentation and consider your own protest or refund posture now, so that if this case (or a related one) succeeds in narrowing or invalidating Section 338’s use here, you are positioned the same way importers who already had suits on file were positioned ahead of the Freestyle World IEEPA class certification.

We outsource customs and freight work to third-party providers — does OFAC’s Pegasus settlement mean we’re on the hook for their screening gaps?

Potentially, depending on the facts, and that risk is exactly why this settlement matters to you even though you aren’t the company that was fined. OFAC announced a $175,015 settlement with Pegasus Worldwide Logistics, Inc. over apparent sanctions violations tied to dealings connected to blocked parties, with commentary describing the underlying conduct as inadequate screening and limited cooperation with the investigation. Importers and manufacturers that route freight through third-party forwarders, brokers, or 3PLs are not automatically shielded by that provider’s own compliance failures — liability can run to whoever benefited from or facilitated the transaction. Treat “know your forwarder” the same way you treat “know your customer”: ask providers for their OFAC screening practices and compliance program documentation before you treat them as a safe pass-through for cross-border freight.

Any update on timing for the forced-labor Section 301 ruling?

No ruling and no schedule, but the argument is now sharper. The Court of International Trade’s panel in Learning Resources v. United States has pressed both sides on USTR’s statutory authority, with the government arguing it was not required to consider each of the 60 trading partners’ individual level of economic development when setting the 10% to 12.5% forced-labor duties. No decision, briefing order, or timeline has followed. The duties remain in effect, remain payable, and remain drawback-eligible under the same terms as existing Section 301 China tariffs (CBP CSMS #69326983). Don’t wait on the ruling to act — document your drawback eligibility now so you can move quickly whichever way the court goes.

Trump and Sheinbaum both say a deal is “very close” — should we start planning around lower tariffs for 2027?

Not yet. The same “very close” language preceded the August breakdown of the Canada deal and this cycle’s own October 16 reported impasse with Mexico, so treat optimistic statements as a signal of direction, not a signed outcome. President Trump said October 23 the U.S. is “very close” to a deal with Mexico, President Sheinbaum said October 20 that Mexico is “already very close” though “there are still some issues,” and Economy Secretary Marcelo Ebrard was in Washington October 23 with talks described as advancing. Mexico is reportedly seeking a car tariff of 15% or below, matching the rate Japan and South Korea pay, along with a USMCA content-counting rebate. No date has been set for a fourth formal round, and Ebrard expects a response only before year-end. Continue budgeting Q4 and early-2027 costs around the current 50% metals and 25% auto rates until there is a signed text.

What is this USMCA content rebate Mexico is asking for, and how would it affect maquiladora operations?

It’s a negotiating proposal, not yet adopted policy, but worth understanding now because it would directly affect how cross-border bills of material are valued. As reported alongside the October 23 talks, Mexico is pushing for a rebate or credit mechanism that would count parts manufactured anywhere within the USMCA bloc (the United States, Mexico, and Canada) toward reducing Section 232 and auto-tariff exposure, rather than only crediting content with Mexican origin. For maquiladoras that source components from U.S. or Canadian suppliers for Mexican assembly, this would broaden what counts as “qualifying” content beyond the current USMCA rules-of-origin framework. Nothing has been signed, but if your bill of materials mixes U.S., Mexican, and Canadian inputs, it’s worth having your broker model what this rebate structure would mean for your effective tariff rate so you’re ready to act if it’s adopted.

Could the U.S. use the same Section 338 mechanism against Mexico that’s now being challenged for Canada?

There’s no indication of that currently, but the new lawsuit’s outcome could matter either way. Section 338 of the Tariff Act of 1930 is a general retaliatory-tariff authority, not a country-specific one, and it currently underlies the bilateral tariffs of up to 50% imposed on Canadian goods after the August deal breakdown. The lawsuit filed October 20 by a New Jersey food importer tests whether that statute was lawfully invoked in the Canada context; a ruling narrowing or invalidating its use there would likely constrain any future use against Mexico as well, while a ruling upholding it would leave the authority available if U.S.-Mexico talks were to break down again. For now, treat this as a case to monitor for its legal reasoning rather than as a signal that Section 338 is imminently coming to Mexican entries.

We depend on rare-earth inputs for auto or electronics components assembled in Mexico — how exposed are we with the November 10 deadline two weeks out?

Meaningfully exposed, and the window to prepare is now short. China’s one-year suspension of its expanded October 2025 rare-earth export controls, covering case-by-case licensing on seven medium and heavy rare earths and extending to foreign-made products with at least 0.1% Chinese-origin rare-earth value, expires November 10, 2026, with no confirmed extension as of this issue. This is separate from the broader U.S.-China tariff truce already extended to January 10, 2027. Analysts broadly expect both governments to renew the suspension, but that is a market expectation, not a reported outcome, and China controls roughly 69% of global rare-earth mining and up to 90% of processing capacity. If your Mexican assembly operations depend on rare-earth magnets, specialty alloys, or components with Chinese-origin rare-earth content, finalize contingency sourcing and inventory positioning in the next two weeks rather than waiting on confirmation either way.