CBP Enforcement Archives | Customs & International Trade Law Blog

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 Jennifer Diaz|2026-10-14T10:22:02-04:00October 14, 2026|U.S. Department of Justice (DOJ)|0 Comments

CBP Issues Two New WROs Against Jordan Garment Factories: What Importers Need to Know

Why importers who diversified out of China to FTA partners are now squarely in CBP’s forced-labor crosshairs — and the five-step package you need before your first detention notice.

Short summary: CBP just issued two Withhold Release Orders against garment factories in Jordan, a U.S. free trade agreement partner. If you diversified out of China, thinking that solved your forced-labor exposure, this action is your wake-up call. Duty-free status is not a compliance shield. For apparel and textile importers, the window to build a defensible admissibility package is now, before a detention notice arrives.

On June 23, 2026, U.S. Customs and Border Protection (CBP) issued two Withhold Release Orders (WROs) against garments produced by Needle Craft Ltd. and Casual Wear Apparel LLC — two garment-manufacturing factories in Jordan. Effective immediately, CBP will detain all garments produced by these two factories at every U.S. port of entry. These are the fifth and sixth WROs of fiscal year 2026, and they push CBP’s active enforcement docket to 58 WROs and eight Findings under 19 U.S.C. § 1307.

If you read only one sentence of this post, read this one: the country you moved your sourcing to to escape China-related forced-labor risk is not safe by virtue of being a U.S. trade-preference partner. Jordan Apparel enters the United States duty-free under the U.S.–Jordan Free Trade Agreement and […]

By Jennifer Diaz|2026-06-23T12:22:55-04:00June 23, 2026|Forced Labor|Comments Off

Forced Labor Enforcement Just Crossed a Border: What CBP’s Serbia Copper WRO Means for Your Supply Chain

Key Takeaways

CBP continues to chase the company, not just the country. Zijin’s parent was already on the UFLPA Entity List for forced labor in China; this Withhold Release Order (WRO) hits its Serbian copper operation on a separate evidentiary basis. Moving production to a “friendly” country does not move you out of CBP’s reach.
Copper just joined the enforcement map. Forced-labor detentions are no longer concentrated in apparel, solar, and cotton. If you import copper—or anything containing it—your supply chain is now in scope, and most copper-reliant importers have done zero forced-labor due diligence.
The burden is on you, and it lands the moment your shipment is detained. Under a WRO, there is no notice and no grace period. You either prove your goods are clean by detailed documentary evidence, or you export or destroy them.

On June 16, 2026, U.S. Customs and Border Protection (CBP) issued a Withhold Release Order against copper and copper products manufactured in Serbia by Serbia Zijin Copper D.O.O.—the fourth WRO of Fiscal Year 2026 and the second targeting a Serbian operation in roughly six months. Effective immediately, CBP personnel at every U.S. port of entry will detain shipments of copper and copper products from this company.

If you read that as another distant enforcement headline, you are missing the part that should concern you. This […]

By Jennifer Diaz|2026-06-19T13:16:26-04:00June 19, 2026|Enforcement, Forced Labor, Supply Chain, U.S. Customs and Border Protection (CBP)|Comments Off

President Trump Orders Sweeping Customs Enforcement Overhaul: Importer Eligibility, Bonds, Penalties, and Foreign IORs Face Major Changes

On June 3, 2026, President Trump signed the Executive Order “Strengthening Customs Enforcement,” directing the Department of Homeland Security (DHS) and U.S. Customs and Border Protection (CBP) to overhaul the rules that govern importers of record (IORs). The accompanying White House Fact Sheet frames the Order as a truly significant tightening of importer responsibilities – higher bonds, mandatory domestic assets, a new “good standing” requirement on all importers, and sharp new limits on foreign IORs. As CBP put it in its announcement, importing into the United States “has for too long been treated as a right and not a privilege.” While the Order has set aggressive deadlines for Customs reforms, it leaves most of the operational details to future rulemaking, and several of those details could reshape day-to-day compliance.

Overview: What the Executive Order Directs

Within 180 days, the Order requires the Secretary of Homeland Security to revise importer eligibility rules under 19 U.S.C. § 1484, § 1498, and § 1623, among other authorities. The most notable changes for IORs will be:

A requirement that every IOR maintain, at all times, a minimum level of tangible domestic assets, bonding, or both — plus an increase in the minimum required bond coverage.

Expanded data and identification requirements, including anticipated import volumes, year organized, ownership and beneficial ownership disclosures, business affiliations, and […]

By Jennifer Diaz|2026-06-04T18:49:48-04:00June 4, 2026|Enforcement, U.S. Customs and Border Protection (CBP)|Comments Off

Jewelry Company Charged in $86M Duty Evasion Scheme

On November 17, 2025, the owner of an Indonesian jewelry company (USB Gold) and two employees were charged with taking part in a scheme to evade over $86 million in duties on jewelry imports.

The employees were arrested and charged with one count of conspiracy to commit wire fraud and were detained. The company co-owner, who was also charged, remains in Indonesia and has not yet been arrested.

The defendants allegedly engaged in a complex scheme to import over $1.2 billion of jewelry and illegally defraud the United States out of more than $86 million in customs duties and tariffs.

The alleged scheme included two parts:

First, UBS Gold made jewelry in Indonesia and shipped it to Jordan, which had a Free Trade Agreement with the United States, before sending it to the United States. The defendants then falsely claimed that UBS Gold jewelry had been manufactured in Jordan, which avoided the duty that would otherwise apply.
Second, when the U.S. announced additional tariffs on Indonesia and Jordan earlier this year, the company began shipping scrap gold from the U.S. to Jordan, which they falsely claimed was gold jewelry that simply needed to be assembled or finished in Jordan. Instead, the defendants and co-conspirators swapped the scrap gold for UBS Gold jewelry made in Indonesia, which they then shipped from Jordan to the U.S. The […]

By Jennifer Diaz|2025-11-26T07:43:23-05:00November 26, 2025|Enforcement, Import, International Trade, Pre-compliance, U.S. Customs and Border Protection (CBP)|Comments Off

CBP Issues Proposed Rule to Enhance Low-Value Shipment Enforcement

U.S. Customs and Border Protection (CBP) announced a Notice of Proposed Rulemaking (NPRM) that would impose new data collection requirements on low-value shipments, also known as de minimis shipments. If adopted, the rule would create a new, alternative process for entering low-value shipments. The new process would require the submission of advance data such as origin, destination, and contents of the shipment.

De Minimis Background

The concept of de minimis shipments into the United States stems from customs regulations aimed at simplifying the importation of low-value goods. The term “de minimis” refers to shipments that fall below a certain value threshold, allowing them to enter the country with minimal duties or taxes.

Historically, the threshold was set at $200 but was raised to $800 in 2016 under the Trade Facilitation and Trade Enforcement Act (TFTEA). This change was designed to reduce administrative burdens on CBP and facilitate faster processing of e-commerce shipments, which were rapidly increasing in volume. Over the last decade, the number of shipments claiming the de minimis exemption has increased significantly, from approximately 140 million a year to over one billion a year.

Today, CBP processes over 4 million de minimis shipments into the U.S. each day. Current regulations require very little information about these shipments, making it increasingly difficult for CBP to identify and intercept high-risk shipments. The U.S. Congress and the Biden Administration have called for de minimis reforms.

The Proposed Rule

The rule proposes the establishment of an enhanced entry process that would require the […]

By Jennifer Diaz|2025-01-17T16:19:01-05:00January 17, 2025|Import, U.S. Customs and Border Protection (CBP)|Comments Off

Customs Classification – A Key Component of an Import Compliance Manual

We are often asked by importers to assist in classifying their products under the Harmonized Tariff Schedule of the U.S. (“HTS” or “HTSUS”). While seeking assistance from expert counsel is a best practice, under the CBP Modernization Act, an importer of record (“IOR”) is the sole party responsible for determining the correct classification of imported goods (and thereby paying the correct amount of customs duties). An IOR must use reasonable care in classifying its product at the time of entry. Should an importer misclassify their products and not pay the appropriate duties to CBP at the time of importation; the importer is exposing itself to potential CBP penalties under 19 U.S.C. 1592. The process of classifying goods can be a tedious process and may require time and research to arrive at the correct HTSUS number for any one product.

This blog expands our prior blog, Crash Course in the Harmonized Tariff Schedule of the United States, and provides additional detail on the classification process and tips for importers to use when deciding on a classification its customs broker will declare to CBP. Importers are encouraged to attend the webinar How to Build and Maintain an Effective Import Compliance Plan on October 6, 2021 (and on-demand) for best practices on how to build and maintain an import compliance plan by addressing common risks associated with the import process – including product classification.

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By Jennifer Diaz|2021-10-01T09:48:07-04:00October 4, 2021|Best Practices, Enforcement, HTS, Import, Pre-compliance, U.S. Customs and Border Protection (CBP)|Comments Off

Jen Diaz to Moderate FCBF Webinar on IPR featuring CBP Branch Chief and UL

Diaz Trade Law is excited to announce that President Jennifer Diaz will be moderating the upcoming FCBF webinar titled “IPR with CBP and UL” with the Chief of the Intellectual Property Rights Branch of U.S. Customs and Border Protection, Alaina van Horn, and UL Brand Protection Manager, Lisa Deere.

The Florida Customs Brokers & Forwarders Association (FCBF) encourages all custom brokers, patent, trademark and all international trade professional to join its Intellectual Property Rights (IPR) with U.S. Customs and Border Protection (CBP) and UL. This one-hour webinar will give custom brokers, importers, and all other international trade professionals the ability to learn and understand CBP’s IPR customs and enforcement.

This webinar will be Friday, September 3, 2021 at 11:30 AM EST.

Register Now!

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By Jennifer Diaz|2021-09-02T16:43:47-04:00September 2, 2021|Best Practices, Counterfeits, Customs Broker, Import, International Trade, IPR, Trademarks and Logos, Seizures, Speaking, U.S. Customs and Border Protection (CBP)|Comments Off

Using WROs to Fight Forced Labor

Forced Labor is the third most lucrative illicit trade, behind only drugs and weapons, and has an annual trade value of roughly $150 Billion. Right now, over 40 million people around the world are victims of some type of forced labor, including modern slavery, human trafficking, etc.

Thankfully, U.S. Customs and Border Protection has been working to curb this inhumane practice.

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FREE World Trade Month Seminar on AD/CVD & CBP ENFORCEMENT

Flyer. Importers, here is your chance to learn all about the hot topic of AD/CVD. In celebration of World Trade Month, Diaz Trade Law is providing the trade community a valuable opportunity to speak direct with Supervisory Import Specialists with U.S. Customs and Border Protection (CBP) and a legal expert to address your questions and concerns relating to CBP’s role in administering and enforcing imports subject to AD/CVD.

In Fiscal Year 2016, CBP Processed $14 billion of imported goods subject to AD/CVD, and collected $1.5 billion in cash deposits. By the end of the fiscal year, $2.8 billion in AD/CVD duties were still owed to the U.S. (dating back to 2001). From fiscal year 2015 to 2016, AD/CVD cash deposits increased over 25
percent. Learn directly from CBP on AD/CVD Compliance and Enforcement! With President Trumps new Executive Order mandating a plan by June 29 “to require importers deemed a risk to U.S. revenue to provide security for AD and CVD liability through bonds and other legal measures”- many questions arise! Now’s your time to ask them!!

You have a limited time to RSVP to this event for FREE!!! Yes, for FREE. We find this information to be invaluable so Diaz Trade Law is sponsoring this event, to bring it to you for FREE. RSVP today! Our full event agenda including the who, what, when, and where is below. Don’t miss […]

By Jennifer Diaz|2021-04-09T13:22:00-04:00April 21, 2017|AD/CVD, Customs Broker, Import, U.S. Customs and Border Protection (CBP)|Comments Off