Category: News & Media

On April 13, 2026, President Trump signed into law S. 1884, the Holocaust Expropriated Art Recovery Act of 2025.  The bill passed the Senate unanimously in December 2025 and the House unanimously in March 2026.  The law is the most significant congressional action on Nazi-era art restitution since the original HEAR Act of 2016, and it carries implications that extend well beyond the museum sector and the Holocaust-era context in which it was drafted.

This alert summarizes the statute; explains why it matters to both claimants and institutional holders; and offers a point we think is usually missed in the first wave of commentary on laws of this kind: property-claims practice is a marathon. The clients who prevail, whether they are heirs pursuing a claim or institutions defending one, are almost always the clients who began documenting, organizing, and preparing years before anyone else understood the case was ripe.

Continue reading “Poblete Tamargo Client Alert | Trump Signs HEAR Act; Congress Overrides Supreme Court on Nazi-Era Art Claims”

From Bloomberg News (March 17, 2026):

“Even if the regime in Havana were to fall, “there is no way to untangle the knot that is the disaster of the Cuban economic system without resolving these cases,” said Mauricio Tamargo, a lawyer with Poblete Tamargo LLP and former chairman of the U.S. Foreign Claims Settlement Commission, the government body that verifies such cases. “These expropriations are at the core of Cuba’s economic problems.”

Read the Bloomberg story, Trump’s Cuba squeeze renews fight over $9 billion property claims.

Dear Clients and Colleagues,

Recent reporting and policy signals regarding Cuba and the broader Caribbean indicate continued volatility in sanctions rather than near-term normalization.

While headlines may suggest “stabilization” or renewed dialogue between the U.S. and Cuba, the underlying enforcement and compliance environment remains dynamic—particularly for shipping, energy-adjacent trade, and counterparties with any Cuba nexus.

Our near-term assessment is straightforward:

U.S. pressure is currently being applied through practical chokepoints—most notably oil, shipping, and logistics. As a result, we expect heightened scrutiny, episodic tightening, and increased operational friction before any meaningful easing occurs.

Continue reading “Cuba & Caribbean Update: General Sanctions Outlook and Practical Risk Mitigation Tips”

Dear Colleagues,

Last week, U.S. Customs and Border Protection (CBP) announced the official launch of the Forced Labor Portal, a new centralized online system that is now mandatory for submitting certain forced-labor–related review requests.

Effective as of January 21, 2026, importers and their representatives must use this Portal to submit the following requests to CBP:

• Withhold Release Order (WRO) admissibility reviews
• Uyghur Forced Labor Prevention Act (UFLPA) applicability reviews
• UFLPA exception requests
• CAATSA (North Korea–related) exception requests

CBP has made clear that email or paper submissions will no longer be accepted for these matters. Requests submitted outside the Portal may result in delays or outright rejection.

The Forced Labor Portal is intended to centralize review intake and assign matters to the appropriate CBP office (Forced Labor Division, Port of Entry, or Center of Excellence and Expertise).

All users must authenticate through LOGIN.gov, and both primary and secondary points of contact must have active LOGIN.gov accounts.

Why this matters:

Detentions and exclusions tied to forced labor enforcement already carry tight deadlines and heavy evidentiary burdens. The Portal adds a new procedural layer that, if not handled correctly, can itself become a point of failure. Incomplete submissions, improper document formatting, or delays in Portal registration can jeopardize admissibility reviews and exception requests.

Recommended next steps for importers:

• Confirm that your internal teams and outside brokers understand the new Portal requirement
• Ensure relevant personnel have active LOGIN.gov credentials
• Review your forced labor response playbooks, including document readiness and translation protocols
• Identify products, suppliers, or regions that may trigger UFLPA, WRO, or CAATSA scrutiny

Poblete Tamargo LLP regularly advises clients on compliance with federal trade laws and regulations and can assist with reviewing and preparing submissions through the Forced Labor Portal.  If you have questions about how this change affects your operations—or if you are facing an active detention or exclusion—we are available to assist.

---

This post is for general informational purposes and does not constitute legal advice. Reading it does not create an attorney-client relationship. Each case turns on its facts. Poblete Tamargo is a boutique national security law and public policy practice advising clients on complex matters, including complex consular matters, wrongful detention by foreign governments, economic sanctions, export controls, and congressional oversight. We also counsel employers and travelers on compliant travel planning, documentation, and government engagement strategies. To discuss a specific situation, contact our team.

By Mike Rodriguez, Senior Policy Advisor

Last week, we introduced INTERPOL: what it is, and what it is not. In this update, we’re sharing a practical note for anyone who has reason to believe they may be the subject of an INTERPOL notice (including a Red Notice). Treat this as a travel risk and address it before you board a plane.

First, talk to counsel. 

Your team at Poblete Tamargo has handled matters involving the misuse of INTERPOL channels and other global alert systems. We’ve seen how certain travelers—dissidents, business leaders, journalists, political activists, and others with cross-border exposure (including business owners)—can face elevated risk depending on the jurisdictions involved.

Second, check what is publicly available.

INTERPOL maintains a public notices database, and we review it regularly on behalf of clients. A critical caution: not all notices are public, so a clean result online does not guarantee you’re in the clear.

Third, consider formal inquiries through the right channels.

Engaging U.S. and foreign authorities (and, in some cases, a Ministry of Justice) can be intimidating and easy to mishandle without experience.  We can make informed, measured inquiries on your behalf and, where appropriate, submit requests to INTERPOL’s Commission for the Control of Files (CCF) in Lyon, France, to determine whether a notice or related data exists. Even when INTERPOL does not share details, in some cases it can still be worth making the request and putting relevant parties on notice.

Continue reading “Travel Preparedness Series #2: INTERPOL (Am I On the List?)”