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So far Jennifer Diaz has created 1131 blog entries.

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

On September 28, 2026, the Department of Justice filed a civil complaint in the U.S. Court of International Trade against Uni-Tile & Marble, Inc. and its CEO, Xin Mian Pan, seeking $67,922,260.09 in unpaid duties and a $222,537,664.95 fraud penalty under 19 U.S.C. § 1592. The complaint alleges that Chinese ceramic tile, wooden cabinets and vanities, and quartz surface products subject to antidumping, countervailing, and Section 301 duties were transshipped through Malaysia, undervalued, misdescribed, and later entered under shell importers of record. In our view, the case is a roadmap for importers of AD/CVD-covered goods, their executives, and their sureties on how one set of entries can move from an EAPA determination to criminal charges and a civil penalty suit. 

Key Takeaways 

  • DOJ filed a civil complaint at the U.S. Court of International Trade on September 28, 2026, against Uni-Tile & Marble, Inc. and its CEO, Xin Mian Pan, under 19 U.S.C. § 1592. 
  • The fraud counts seek $67,922,260.09 in unpaid duties and a $222,537,664.95 penalty, with gross negligence and negligence pleaded in the alternative. 
  • The complaint alleges transshipment through Malaysia, undervaluation, misdescription, and entries under shell importers of record covering approximately 503 entries. 
  • The civil suit follows an EAPA evasion determination, CBP penalty proceedings, and a separate criminal indictment that also […]
By |2026-10-14T10:22:09-04:00October 13, 2026|U.S. Department of Justice (DOJ)|0 Comments
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Breaking Trade News: CAPE Phase 3 Live, DOJ Trade Fraud Directive, Outbound Investment Penalty

This week’s recap of the latest customs and international trade news:  

U.S. Customs and Border Protection (CBP) 

  • Phase three of the Consolidated Administration and Processing of Entries (CAPE) refund system was deployed by CBP on October 6. Phase 3 covers finally liquidated entries from importers that filed suit at the CIT and for which the Court has ordered reliquidation. 
  • CBP issued a proposed rule that would create a framework for low-value imports after the end of de minimis and formally establishing new informal Entry Type 13 for merchandise entering through the mail. Comments are due December 7. 
  • CBP’s Agriculture and Prepared Products Center of Excellence and Expertise (APP) in Miami uncovered a tariff evasion scheme involving tuna caught by foreign-flagged vessels. The investigation uncovered over $8M in lost revenue and almost $9M in expected penalties.

Department of Justice (DOJ) 

  • On October 1, 2026, DOJ’s National Fraud Enforcement Division issued Directive 26-12, which makes trade fraud a corporate enforcement priority and lists ten factors prosecutors must weigh in deciding whether to charge a company.  

U.S. Trade Representative (USTR) 

  • USTR announced a public consultation process ahead of the 2027 joint review of the United States-Mexico-Canada […]
By |2026-10-09T12:11:17-04:00October 9, 2026|news, Snapshot|0 Comments
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CBP Proposes Bonds and Earlier Filing for Low-Value Informal Entries: Comments Due December 7 

U.S. Customs and Border Protection (CBP) has issued a Notice of Proposed Rulemaking (NPRM) for Low-Value Shipments that would change informal entry requirements for shipments valued at $2,500 or less, including shipments arriving through international mail. The proposal would add a bond requirement for informal entries, move the Type 11 filing deadline earlier, and create a new electronic Entry Type 13 for mail. Importers, e-commerce sellers, licensed customs brokers, and carriers that handle low-value shipments are affected, and comments are due December 7, 2026. 

Key Takeaways 

  • CBP proposes that all Type 11 (informal) and new Type 13 (informal mail) entry filers obtain a basic importation and entry bond, single transaction or continuous, before release. 
  • The proposed Type 11 filing deadline moves from “within 15 calendar days after landing,” to “upon or before the date of importation”, and Type 11 entries would be filed electronically. 
  • A new Entry Type 13 for international mail of $2,500 or less would be filed electronically by the owner or purchaser in ACE or by a licensed customs broker. 
  • Carriers filing inward manifests would report the mail tracking number, and unentered mail of $2,500 or less would be considered abandoned after 15 days. 
  • Comments are due December 7, 2026, under docket USCBP-2026-0298 on regulations.gov. 

Low-Value Shipments Face New Entry Requirements 

CBP […]

By |2026-10-09T11:49:46-04:00October 9, 2026|ACE, Customs Broker, Import, U.S. Customs and Border Protection (CBP)|0 Comments
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BIS Announces $2 Million Settlement with Lambda Research Corporation for 66 Export Control Violations 

On October 2, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a $2 million administrative settlement with Massachusetts-based Lambda Research Corporation involving 66 alleged violations of the Export Administration Regulations (EAR). The case involved exports of optical and illumination design software, automatic software updates, and transactions with parties on the Entity List and Unverified List. 

Key Takeaways 

  • EAR99 does not mean unrestricted. Even software classified as EAR99 may require an export license when the recipient is on the BIS Entity List. 
  • Automatic software updates can constitute exports. BIS charged Lambda with violations involving software updates transmitted to restricted parties after their addition to the Entity List. 
  • Restricted-party screening must be ongoing. A customer who was not restricted when a transaction began may become subject to licensing requirements later. 
  • Distributors do not eliminate export compliance obligations. Exporters must evaluate the actual end users of their products, including transactions conducted through intermediaries. 
  • The Unverified List creates additional compliance requirements. Certain transactions involving Unverified List parties require a UVL statement even when an export license is not otherwise required. 
  • Informal compliance efforts are insufficient. BIS cited Lambda’s lack of written export compliance procedures, employee training, and designated compliance personnel. 
  • Voluntary self-disclosure does not eliminate penalties. […]
By |2026-10-09T11:35:03-04:00October 9, 2026|EAR, Enforcement, Export, penalty, U.S. Bureau of Industry and Security (BIS), Uncategorized|0 Comments
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Treasury’s First Outbound Investment Penalty: $200,000 Against Amidi LLC 

On October 7, 2026, the U.S. Department of the Treasury announced the first civil penalty issued under its Outbound Investment Security Program (OISP): $200,000 against Amidi LLC, the U.S. parent company of the organization known as Plug and Play Tech Center, for failing to notify Treasury of an investment its Chinese fund subsidiary made in a Chinese embodied artificial intelligence company. 

The underlying investment was approximately $92,478. U.S. investors, venture funds, accelerators, and corporates with offshore investment vehicles should take note: the notification obligation reaches transactions by a U.S. person’s controlled foreign entities, and Treasury has now penalized a missed filing on a small deal. 

Key Takeaways 

  • Treasury imposed a $200,000 civil penalty on Amidi LLC for failing to notify Treasury of an investment of approximately $92,478 in a Chinese AI and robotics company. 
  • The investment was made by Amidi’s Chinese fund subsidiary. The OISP regulations require a U.S. person to notify Treasury of a notifiable transaction by its controlled foreign entity. 
  • The current rules contain no general de minimis threshold for notification, and the existing regulations at 31 CFR Part 850 remain in effect while Treasury implements the COINS Act. 

What Happened 

On April 19, 2025, a Chinese fund owned by Amidi invested approximately $92,478 in Shanghai Qiongche Intelligent Technology Company Limited (Noematrix), […]

By |2026-10-09T11:26:45-04:00October 9, 2026|U.S. Department of Treasury|0 Comments
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