Aldero Partners Launches Dual-Track IEEPA Tariff Refund Recovery Practice for U.S. Importers

New York-based firm offers contingency-based recovery and outright claim acquisition as CBP builds CAPE refund portal targeting mid-April launch

NEW YORK, NY, UNITED STATES, March 23, 2026 /EINPresswire.com/ -- Aldero Partners LLC, a New York-based financial services firm, today announced the formal launch of its IEEPA (International Emergency Economic Powers Act) tariff refund recovery practice. The firm offers U.S. importers of record two engagement structures: contingency-based recovery under which importers pay nothing unless refund proceeds are collected, and outright claim acquisition under which Aldero purchases verified refund claims for immediate cash at a negotiated discount to face value.

The launch follows the U.S. Supreme Court's February 20, 2026 ruling in Learning Resources, Inc. v. Trump (No. 24-1287), which held 6–3 that IEEPA does not authorize the President to impose tariffs. The decision invalidated all IEEPA-based duties—including fentanyl-related tariffs on Canadian, Mexican, and Chinese imports, reciprocal tariffs on virtually all U.S. trading partners, and targeted duties on Venezuelan, Brazilian, Indian, and Russian goods—collected between February 4, 2025 and February 24, 2026.

The Refund Landscape
According to filings before the U.S. Court of International Trade (CIT) in Atmus Filtration, Inc. v. United States (Court No. 26-01259), U.S. Customs and Border Protection (CBP) collected approximately $166 billion in IEEPA duties across more than 53 million entry summaries from over 330,000 importers of record. The Penn Wharton Budget Model projects total refund exposure at up to $175 billion. Under 19 U.S.C. § 1505, CBP owes interest on late refunds at the IRS underpayment rate, and industry estimates place aggregate interest accrual at approximately $650 million per month.

CBP is developing the Consolidated Administration and Processing of Entries (CAPE) system—a new module within its Automated Commercial Environment (ACE) platform—to process claims at scale. As of CBP's March 19, 2026 declaration to the Court, CAPE's Claim Portal was 73% complete, Mass Processing at 45%, Review and Liquidation/Reliquidation at 80%, and the Refund component at 60%. The CIT's March 19 order expanded the scope of prior rulings to include IEEPA tariffs on Brazil and India, and warned the importing community that for entries approaching the 180-day protest deadline under 19 U.S.C. § 1514(a), the administrative window is already active and projected to begin closing in August 2026.

Aldero's Dual-Track Recovery Model
Aldero's primary engagement structure is contingency-based recovery. The firm manages the full refund lifecycle—from ACE data analysis and Harmonized Tariff Schedule (HTS) code classification through CAPE Declaration preparation, CBP protest filing, and CIT proceedings—at no cost to the importer unless funds are recovered.

For importers seeking immediate liquidity, Aldero also acquires verified refund claims outright through a proprietary Claim Purchase Agreement incorporating true-sale doctrine protections, simultaneous closing mechanics—including CBP Form 4811 third-party refund designation, Power of Attorney, and UCC-1 (Uniform Commercial Code Financing Statement) filing—and downstream clawback protections. CBP's March 12 declaration confirmed that CAPE will support Form 4811 designations, enabling refund proceeds to be remitted directly to a designated payee.

Market Context
While institutional buyers have moved aggressively on large IEEPA refund positions, a significant portion of the 330,000+ affected importers remain underserved. Fewer than 10% of eligible importers have completed the ACE Secure Data Portal and ACH (Automated Clearing House) enrollment required for CBP to process any disbursement. Many lack dedicated customs counsel, and an increasing number face downstream clawback demands from customers asserting contractual or equitable rights to a share of the refund.

"The Court's ruling created a clear legal entitlement, but the operational reality of recovering these funds is more complex than most importers appreciate," said a principal at Aldero Partners. "Between CAPE system dependencies, rolling liquidation deadlines, and downstream clawback litigation, there is substantial value in a dedicated recovery partner who understands the mechanics at the entry-summary level."

Engagement and Referral Program
Aldero offers a no-cost preliminary assessment using ACE ES-003 entry summary data to identify refundable HTS classifications, estimate exposure including interest, and flag AD/CVD (antidumping/countervailing duty) or other CAPE carve-outs. A referral program for licensed customs brokers and trade attorneys pays fees on successful recoveries or closed purchases originating from their introductions.

About Aldero Partners LLC
Aldero Partners LLC is a New York-based financial services firm focused on the acquisition and recovery of U.S. international trade receivables. The firm offers contingency-based recovery, outright claim purchasing, and structured advisory for importers of record navigating the IEEPA refund landscape. alderopartners.com

Aldero Partners LLC
Aldero Partners LLC
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info@alderopartners.com
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