DOJ Seeks $290 Million From Uni-Tile and CEO in Customs Fraud Suit

The Justice Department is seeking approximately $290.4 million in unpaid duties and fraud penalties from Uni-Tile & Marble Inc. and its chief executive officer, Xin Mian Pan, in a civil customs enforcement action that examines their alleged role in imports entered through other companies.

Announced October 7, the lawsuit asks the U.S. Court of International Trade to hold Uni-Tile and Pan jointly and severally liable for $67.9 million in unpaid duties and $222.5 million in fraud penalties. The government alleges that the defendants evaded duties on Chinese merchandise through transshipment, undervaluation and false product descriptions.

“A new DOJ customs fraud case puts the spotlight on who is actually behind an import transaction,”  James Kim, an international trade partner at ArentFox Schiff, wrote in a LinkedIn post discussing the case.

The government alleges that the conduct spanned September 2018 through August 2023 and involved 503 customs entries covering wooden cabinets and vanities, quartz surface products, ceramic tiles and other merchandise. According to DOJ, materially false statements and omissions deprived the United States of duties owed on those imports.

Shell Companies

A central issue is the defendants’ alleged use of shell companies after U.S. Customs and Border Protection opened an Enforce and Protect Act investigation in March 2022. The civil complaint alleges that the defendants shifted imports to other importers of record to conceal their involvement and continue avoiding duties.

“One detail deserves a closer look,” Kim wrote. “After CBP opened an Enforce and Protect Act investigation, the defendants allegedly stopped using Uni-Tile as the importer of record and began using shell companies to continue the alleged duty evasion.”

The complaint identifies approximately 130 entries and one attempted entry made through five alleged shell importers. To connect those transactions to the defendants, the government cites communications directing customs clearance through another company, invoices involving Pan and shipment markings bearing Uni-Tile’s business addresses. Those allegations place the defendants’ asserted control over the transactions at the center of the case. Civil complaint.

“The civil complaint includes an aiding-and-abetting theory for entries made through other importers of record,” Kim wrote. “The government’s case reaches beyond the name on the entry.”

Adds to Prior Charges

The civil action invokes 19 U.S.C. § 1592, the Tariff Act provision addressing material false statements and omissions in import transactions. It also follows a separate criminal prosecution: federal prosecutors announced charges in December 2025 against Pan, Uni-Tile and other defendants, including conspiracy, wire fraud, smuggling and international money laundering charges.

“This is a Section 1592 customs enforcement action, alongside previously announced criminal charges,” Kim wrote. “It illustrates how the same alleged conduct can generate multiple enforcement proceedings.”

For trade counsel and compliance professionals, the case presents two issues to follow: how the government proves an executive’s participation in allegedly false entries, and how it establishes responsibility for transactions conducted through separate importing entities.

The amounts sought are demands for relief, not an adjudicated recovery. The civil allegations remain unproven, and criminal charges do not establish guilt.

“These remain allegations, and liability has not been determined,” Kim wrote. “How the government establishes the defendants’ involvement across the different importing entities will be worth watching.”