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October 2025, question 20
Broker Compliance · Broker licensing and duties
Mr. Jones, a buying agent with power of attorney for importer American Widgets, employs licensed customs broker Ms. Smith for the transaction of customs business and Speedy Freight Forwarder for the transportation of merchandise on behalf of American Widgets. Mr. Jones does not have a customs broker license. American Widgets' imported merchandise was not purchased on a delivered duty-paid basis. Ms. Smith executed a power of attorney directly with American Widgets. Of the following choices, what additional action must Ms. Smith take for billing purposes?
- Ms. Smith must transmit either a copy of her bill for services rendered or a copy of the entry to American Widgets, unless American Widgets waives transmittal.
- Ms. Smith must pay a finder's fee to Mr. Jones for the referral of American Widgets' customs business.
- Ms. Smith must execute a power of attorney directly with Speedy Freight Forwarder.
- Ms. Smith must transmit directly to Speedy Freight Forwarder a copy of the brokerage charges.
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CBP's answer: A. A: Ms. Smith must transmit either a copy of her bill for services rendered or a copy of the entry to American Widgets, unless American Widgets waives transmittal.
When an unlicensed person who is not the actual importer employs the broker, 111.36(a) requires the broker to send the actual importer either a copy of the bill for services or a copy of the entry, unless the goods were bought delivered duty-paid or the importer waived it in writing. Here Jones, an unlicensed buying agent, hired Smith and the goods were not delivered duty-paid, so A. No finder's fee, forwarder POA or forwarder billing is required.
the broker must transmit to the actual importer either a copy of his bill for services rendered or a copy of the entry 19 CFR 111.36(a)
Search for: Employment by unlicensed person other than importer
CBP's key cites: 19 CFR 111.36(a)
Question and key from CBP's October 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).