CustomsBrokerLicenseExam

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April 2024, question 8

Broker Compliance · Broker licensing and duties

Which of the following scenarios demonstrates that a customs broker may have failed to maintain responsible supervision and control over their customs business?

  1. John Smith Customs Brokerage (Smith) terminated Sally Johnson's (Johnson) employment. Johnson was listed in Smith's Automated Commercial Environment (ACE) portal account as the knowledgeable point of contact to be available to CBP during and outside of normal operating hours. Smith updated Johnson's employee record but did not designate a new knowledgeable point of contact in ACE. CBP has been unable to contact Smith for over six months.
  2. Countrywide Customs Brokerage (Countrywide) has ten offices across the United States under a National Permit with an approved supervision plan. Two of these offices do not have a licensed broker on site and have not had one for six months. Although Countrywide has not requested a waiver, Countrywide has a licensed broker conduct a supervisory visit twice a week to those offices.
  3. National Customs Brokerage (National) unwittingly hired James Jones, Sr., a convicted felon who committed embezzlement ten (10) years ago. On his employment application, Jones stated that he did not have any felony convictions and used another person's social security number. National did not seek a waiver to employ a convicted felon.
  4. Trustworthy Customs Broker Co. (Trustworthy) received $10,000.00 from Sally Doe, an importer of handblown glass figurines. Sally has designated Trustworthy to make payment for all imports over the course of a year, and to collect any refunds issued by CBP. Sally owes $4,000.00 in estimated duties for her most recent acquisition of figurines. Trustworthy remitted payment to CBP within 12 days of the figurines’ arrival at the Port of Long Beach.
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CBP's answer: A. A: John Smith Customs Brokerage (Smith) terminated Sally Johnson's (Johnson) employment. Johnson was listed in Smith's Automated Commercial Environment (ACE) portal account as the knowledgeable point of contact to be available to CBP during and outside of normal operating hours. Smith updated Johnson's employee record but did not designate a new knowledgeable point of contact in ACE. CBP has been unable to contact Smith for over six months.

A broker with a national permit must keep a knowledgeable point of contact available to CBP and keep that information current in the EDI system. Smith never replaced the departed contact, and CBP could not reach the firm for six months, which shows a lapse in responsible supervision and control. The other scenarios describe supervisory visits, an unwitting hire, or timely payment.

must maintain accurate and current point of contact information in a CBP-authorized electronic data interchange (EDI) system 19 CFR 111.3(b)

Search for: knowledgeable point of contact

CBP's key cites: 19 CFR 111.3(b); 19 CFR 111.28(a)

Question and key from CBP's April 2024 exam and answer key. The walk-through is ours; quotes are from the pinned editions in the reference viewer (HTSUS 2026 Basic, 19 CFR 2025 edition).