CBP Initial Determination Malaysia Transshipping February 2022

are location stamped at a location which is not Sanctuary Stone ’ s location , which is also discussed above . ¹⁸¹

CBP obtained information from the CCM for the MSW Companies . ¹⁸² These five companies all share a web of employees , directors , shareholders , and addresses , and as they are operated by the same individuals at varying addresses , and all supply certain importers under investigation with QSP , CBP finds the MSW Companies act as a single entity . ¹⁸³ CCM data indicates the dates of incorporation of these companies . When asked how long it has been opened for business , MSW indicated it has been in operation “ more than 10 years .” ¹⁸⁴ This statement is false . Record information from CCM indicates MSW was incorporated December 20 , 2019 . ¹⁸⁵ MSW also indicated its owner is Chong Wen How . ¹⁸⁶ This is another false statement because the owner of MSW is Mr . Huang . ¹⁸⁷

MSW submitted a document which indicates it purchased finished goods from Sanctuary Stone . ¹⁸⁸ The invoice from MSW to Kingway is dated February 15 , 2021 . ¹⁸⁹ However , MSW indicated it purchased QSP from Sanctuary Stone on March 19 , 2021 , over a month after the sale to Kingway . ¹⁹⁰ As such , CBP finds this document is not responsive to the CF28 . Moreover , a nearly identical purchase document was submitted by MSI in Big D ’ s CF28 Response . ¹⁹¹ These purchase documents appear to have undergone some minor alterations to make them appear to be different ; however , there are many similarities . For example , the account number for MSW is identical to that of MSI , but the accounts have different names . ¹⁹² Moreover , the documents are time stamped to the identical thousandth of a second , “ 9:39:22 ,” and are both dated March 19 , 2021 . ¹⁹³ In addition , the sender ’ s and receiver ’ s reference numbers are identical , as well as the monetary amounts and the message to the beneficiary . ¹⁹⁴ There is nothing in MSW ’ s purchase document which ties it to the entry in question ( e . g ., invoice number , purchase order number , production records , etc .). In sum , CBP finds this document is not responsive to the CF28 and appears to have been created in response to CBP ’ s request for information , rather than a document kept by MSW in the normal course of business .

In the CF28 , CBP requested that Kingway provide entry transaction information including the original commercial invoices , proof of payments , CF7501s , contracts , purchase orders , country of origin documentation , and all bills of lading . CBP noted that the proof of payment should tie

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See Malaysian Companies Memo at Sanctuary Stone for a map indicating the distance between these two locations . This is also discussed in the “ Big D ” section above .

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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 reports we received for each company .