frustrate the ability of CBP [U.S. Customs and Border Protection] to implement and carry out the terms of the Tariff Act of 1930 ... with regard to examination of merchandise imported to the Port of Miami on or about June 4, 2011 ... by causing their attorneys ... to submit to CBP correspondence dated June 30, 2011 and a Petition for Expedited Procedures and Early Release dated July 3, 2012, containing false and fraudulent information and phony supporting documentation, falsely alleging provenance for items of Chinese fine art contained in the shipment, including false information related to items dated to the period pre-907 A.D ., in order to frustrate the ability of CBP to accurately determine whether such items were lawfully imported into the United States.
invoices accompanying the shipment indicated that the entire contents had originated in Florida and were being returned to the United States after having been shipped to Hong Kong for a trade show. After the items were interdicted by U.S. Customs and Border Protection (CBP) inspectors, Francois B. Lorin and others created false documents to justify provenance for certain items in the shipment that were prohibited from entering the United States without such provenance. Thereafter, Lorin & Son, LLC and Francois B. Lorin, through counsel, filed a petition for remission with CBP and provided supporting materials, in which they argued for release of the interdicted items by using false invoices and providing other false information. The invoices that were submitted were backdated, falsely claimed that items had been acquired from third-parties before the MOU date, and otherwise falsely claimed that these documents established “proof” that the items could be lawfully imported.