CBP Initial Determination Malaysia Transshipping February 2022

production steps are found on Vemy Stone ’ s website . ¹³⁹ MSI did not submit the requested narrative of the manufacturing process . ¹⁴⁰

MSI stated that Sanctuary Stone is located at No . 223 , Jalan 2A , KG , Baru Subang , 40150 Shah Alam , Selangor Darul Eshan , Malaysia , which is confirmed by the information CBP placed on the record of this investigation . ¹⁴¹ Two of the photographs provided by MSI , which do not appear on Vemy Stone ’ s website , have a location stamp , of “ Pelabuhan Klang ,” or “ Port Klang ” in English . ¹⁴² CBP notes Port Klang has a postal code of 42000 and is approximately 33 kilometers from Sanctuary Stone ’ s location , thus , these photographs provided by MSI were not taken at Sanctuary Stone because the location stamp is incorrect . ¹⁴³ Moreover , these photographs appear dissimilar to those found on Sanctuary Stone ’ s website for the reasons noted above . ¹⁴⁴

CBP obtained information from the Companies Commission of Malaysia ( CCM ) with respect to the following companies : LLWF , Monthong , MSI , MSW , and South Wales . ¹⁴⁵ CBP finds these five companies all share a web of employees , directors , shareholders and addresses . ¹⁴⁶ For example , MSI shares two addresses with MSW and Monthong , one address with LLWF , and while it shares no address with South Wales , South Wales shares two addresses with LLWF . ¹⁴⁷ Jia Hui Ng is the director ( or co-director ) for all five companies , and Mahani Binti Asmuni is the secretary for MSW , MSI , Monthong , and LLWF . ¹⁴⁸ Mr . Feng ( discussed above in the “ Initiation ” section ) is the owner of MSI and Monthong . ¹⁴⁹ As these five companies are operated by the same individuals at varying addresses , and supply certain importers under investigation with QSP , CBP finds these companies act as a single entity which CBP collectively refers to as the MSW Companies . ¹⁵⁰ Thus , when MSI provided information in an attempt to respond to our number

requests for information for entry [ ] 8665 , those same company officials from MSI could

number have also provided information for entry [ ] 3764 .

In addition , CCM data indicates the dates of incorporation of these companies . When asked how long it has been opened for business , MSI indicated it has been in operation “ more than 10

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See Malaysian Companies Memo at Vemy Stone .

MSI submitted a photograph of the products it produces and presumably sells to Big D ; however , an image search for this photograph reveals it is from Home Depot . See Memo to the File , “ Consolidated EAPA Investigation 7657 : Information Pertaining to the Importers Under Investigation ,” dated February 8 , 2022 ( U . S . Importers Memo ) at “ Home Depot .” There is no record evidence which indicates Big D or MSI are suppliers to Home Depot .

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See Big D ’ s CF28 Response ; Malaysian Companies Memo at Sanctuary Stone .

142

See Big D ’ s CF28 Response .

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See Malaysian Companies Memo at Sanctuary Stone for a map indicating the distance between these two locations .

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The photographs appear similar to those found on Vemy Stone ’ s website .

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See Malaysian Companies Memo at “ Companies Commission of Malaysia ” for a summary chart which indicates the various overlaps between these five companies , and the CCM reports we received for each company .