DOJ Sues Tile Importer and CEO for $67.9 Million in Duties Over Alleged Transshipment and Shell Importers of Document

On September 28, 2026, the Department of Justice filed a civil criticism within the U.S. Court of International Trade towards Uni-Tile & Marble, Inc. and its CEO, Xin Mian Pan, in search of $67,922,260.09 in unpaid duties and a $222,537,664.95 fraud penalty below 19 U.S.C. § 1592. The criticism alleges that Chinese ceramic tile, picket cupboards and vanities, and quartz floor merchandise topic to antidumping, countervailing, and Section 301 duties had been transshipped by Malaysia, undervalued, misdescribed, and later entered below shell importers of file. In our view, the case is a roadmap for importers of AD/CVD-covered items, their executives, and their sureties on how one set of entries can transfer from an EAPA willpower to legal costs and a civil penalty go well with. 

Key Takeaways 

• DOJ filed a civil criticism on the U.S. Court of International Trade on September 28, 2026, towards Uni-Tile & Marble, Inc. and its CEO, Xin Mian Pan, below 19 U.S.C. § 1592. 

• The fraud counts search $67,922,260.09 in unpaid duties and a $222,537,664.95 penalty, with gross negligence and negligence pleaded within the different. 

• The criticism alleges transshipment by Malaysia, undervaluation, misdescription, and entries below shell importers of file overlaying roughly 503 entries. 

• The civil go well with follows an EAPA evasion willpower, CBP penalty proceedings, and a separate legal indictment that additionally names a licensed customs dealer. 

• In our view, importers of AD/CVD-covered items ought to confirm each importer of file on their entries and assist origin with manufacturing proof now. 

What the Government Alleges 

The Department of Justice introduced the go well with on October 7, 2026, describing the customs duties and fraud penalties sought as exceeding $280 million. DOJ acknowledged that the criticism seeks to implement CBP’s demand for duties and penalties below 19 U.S.C. § 1592(a) towards Uni-Tile and Mr. Pan collectively and severally. Read the DOJ press release and the complaint. 

According to the criticism, Uni-Tile is a California company with areas in Hayward, San Francisco, and San Jose, and Mr. Pan served as its CEO and CFO and managed its every day operations. The criticism covers roughly 503 entries made between roughly September 22, 2018, and August 28, 2023. 

The criticism describes 4 alleged practices: 

• Transshipment. Routing Chinese merchandise by Malaysia and declaring Malaysia because the nation of origin, utilizing two Malaysian firms the criticism identifies as South Wales Furniture SDN BHD and LLWF Cabinets & Stone SDN BHD. 

• Undervaluation. Declaring entered values decrease than the quantities really paid to the Chinese producers. 

• Misdescription. Entering quartz floor merchandise as synthetic stone or granite, which the criticism states should not topic to the AD/CVD orders. 

• Shell importers of file. According to the criticism, after a CBP investigation, entries had been filed below different firms as importer of file, together with Green Mountains Trading, Jos Materials, Uncle John Granite and Marble, New Generation Surfaces, and Santa Flo Commercial. The criticism counts roughly 372 entries itemizing Uni-Tile as importer of file and roughly 130 entries, plus one tried entry, itemizing the shell firms. 

The merchandise falls below AD/CVD orders on three Chinese product traces: ceramic tile, picket cupboards and vanities, and quartz floor merchandise. For ceramic tile, the criticism lists a mixed AD/CVD money deposit fee of 689.50%. The criticism additionally cites Section 301 duties of 25% advert valorem on sure Chinese merchandise. 

Four Counts, Three Culpability Levels 

The authorities pleads fraud as its major principle, with gross negligence and negligence within the different, and a separate depend for aiding and abetting the shell importers of file. The quantities under are as acknowledged within the criticism. 

Under 19 U.S.C. § 1592(c)(1), the utmost civil penalty for a fraudulent violation is the home worth of the merchandise. The criticism identifies $222,537,664.95 as that home worth. The criticism states that Uni-Tile and Mr. Pan haven’t paid any a part of CBP’s penalty or obligation demand. 

The criticism additionally identifies Hua Liang Xie, proprietor of Oriox Customs Broker Co., as Uni-Tile’s major customs dealer. Mr. Xie is just not a defendant within the civil case. 

How CBP and DOJ Built the Case 

The civil criticism and the U.S. Attorney’s Office launch on the legal case lay out the next sequence. 

The Parallel Criminal Case 

On December 18, 2025, the U.S. Attorney’s Office for the Northern District of California introduced an indictment charging Mr. Pan, Uni-Tile & Marble, Uni-Stone & Cabinet, Hua Liang Xie, whom the discharge describes as a licensed customs dealer, PRC nationwide Jinhua Wang, and Shenzhen Top & Profit International Forwarding Co. Ltd. The costs embody conspiracy, conspiracy to commit wire fraud, wire fraud, smuggling, and entry of products by way of false statements, with transnational cash laundering costs towards Mr. Pan and his two firms. 

The legal launch alleges greater than $109 million in evaded duties throughout roughly 520 shipments. Those figures come from the legal launch and differ from the figures pleaded within the civil criticism. The launch states that an indictment is barely an allegation and that the defendants are presumed harmless until confirmed responsible past an affordable doubt. For the civil case, DOJ’s press launch states that the claims within the criticism are allegations solely and that legal responsibility has not been decided. 

DTL’s learn: This sequence reveals how a single set of entries can produce administrative, legal, and civil publicity on the similar time, for the corporate, its govt, and its customs dealer. In our expertise, the EAPA stage is the place an importer nonetheless has probably the most room to form the file, and the pre-penalty and penalty levels are the executive home windows to contest the culpability stage earlier than a case is referred to DOJ. 

What Importers Should Do Now 

The following are DTL’s suggestions for importers of merchandise lined by AD/CVD orders or Section 301 duties, notably items that transfer by third nations. 

1. Confirm the importer of file on each entry. Pull your ACE experiences and evaluate the importer of file on every entry towards the corporate that ordered, paid for, and owns the products. An unfamiliar importer of file on items you management is a warning signal.
2. Support nation of origin with manufacturing proof. For items from transshipment-risk nations, maintain manufacturing facility manufacturing data, uncooked materials sourcing, and fee trails, not solely certificates of origin. See our Country of Origin Determination & Marking companies.
3. Treat an EAPA discover, CF-28, or pre-penalty discover as an enforcement occasion. Engage customs counsel earlier than you reply. See our pages on CBP Form 28 and CBP 1592 Penalties.
4. Evaluate prior disclosure and the DOJ path collectively. As we defined in A Warning for Importers: A CBP Prior Disclosure Does Not Count for DOJ, a CBP prior disclosure is just not a voluntary self-disclosure to DOJ. See additionally our Prior Disclosures to CBP web page
   
5. Review your customs dealer relationship. The indictment names a licensed customs dealer as a defendant. Confirm that your dealer’s entry practices match your directions and your data.
6. Know your particular person and bond publicity. The civil criticism names the CEO individually, and CBP issued obligation calls for to the sureties. Executives and finance groups ought to perceive each earlier than an enforcement matter begins.
7. Diligence home suppliers of imported items. As our October 8 article explains, firms that purchase imported items can face legal responsibility for knowingly buying merchandise imported opposite to legislation, even when they by no means handled CBP. 

Where the Case Stands and How DTL Can Help 

The civil criticism was filed on September 28, 2026, and it describes the legal case, United States v. Xin Mian Pan, et al., Cr. No. 25-0428 (CRB) (N.D. Cal.), as pending. Status of later docket exercise in both case not confirmed as of October 13, 2026. 

Diaz Trade Law represents importers in CBP penalty proceedings below 19 U.S.C. § 1592, EAPA investigations, prior disclosures, and DOJ commerce fraud inquiries. For extra on the present enforcement surroundings, see: 

If your organization has acquired an EAPA discover, a CF-28, a pre-penalty discover, or a DOJ inquiry, contact Diaz Trade Law at 305-456-3830 or go to diaztradelaw.com.