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April 2025, question 9
Broker Compliance · Penalties, recordkeeping and prior disclosure
Forty-two days ago, a customs broker knowingly hired a person convicted of a felony. At no point has the customs broker sought approval for this hire from CBP. Additionally, CBP is not aware of this hire. As of today, what is the heaviest single maximum penalty that can be assessed by CBP against this broker for not seeking approval from the appropriate Executive Director, Office of Trade for the felon's continued employment?
- $5,000.00 penalty
- $10,000.00 penalty and a suspension of their license
- $25,000.00 penalty
- $30,000.00 penalty and revocation of their license
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CBP's answer: C. C: $25,000.00 penalty
Appendix C of Part 171 gives a $25,000 penalty for knowingly employing a convicted felon without seeking approval. The $5,000 penalty applies only if the broker applies late within the period, and $30,000 applies if approval was denied and employment continued. Here approval was never sought and CBP is not aware, so $25,000.
A $25,000 penalty for knowingly employing any convicted felon without seeking approval for employment. 19 CFR Part 171
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CBP's key cites: 19 CFR Part 171
Question and key from CBP's April 2025 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).