Uni-Tile Shows Why EAPA Findings Need DOJ Follow-Through

A 2021 EAPA allegation (opens in a new tab) by the American Kitchen Cabinets Alliance led CBP to find in 2022 that Chinese cabinets were transshipped through Malaysia to evade duties. DOJ alleges the scheme extended to quartz and ceramic tile, involving undervaluation and false descriptions. After CBP began investigating, shell importers allegedly allowed the operation to continue.

The government did not stop at CBP's finding. Criminal charges (opens in a new tab) followed in December 2025 against Uni-Tile, its CEO and others. When CBP's payment demands went unmet, DOJ pursued civil action (opens in a new tab), seeking $67.9 million in unpaid duties and $222.5 million in fraud penalties. Both cases remain unresolved; the allegations have not been proven.

This coordinated civil and criminal response deserves recognition and should be replicated. Yet our KCMA case study shows that favorable EAPA findings often fail to deliver results. Replication requires DOJ capacity and specialized trade-fraud expertise in U.S. Attorneys' Offices and Main Justice. Success means collecting duties, imposing penalties exceeding the gains from fraud, and holding culpable individuals accountable. A settlement leaving the financial rewards of misconduct intact would fail to deter.