CustomsBrokerLicenseExam

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October 2026, question 17

Broker Compliance · Broker licensing and duties

Bob Broker, an individual licensed customs broker, is employed by Fine Furniture, an importer. Fine Furniture makes classification decisions, valuation decisions, prepares entry summaries, and communicates directly with CBP on technical matters. As part of his employment, Bob Broker uses his individual customs broker license, filer code, and national permit to file customs entries for Fine Furniture's imported merchandise. Fine Furniture compensates Bob Broker as a salaried employee. CBP has determined that Fine Furniture is conducting "customs business" without an organizational broker’s license, and Bob Broker is allowing his individual broker’s license to be used by an unlicensed entity to transact “customs business.” This arrangement has been ongoing for 10 separate import transactions. What is the maximum civil penalty that CBP could assess against Fine Furniture for Fine Furniture’s violations?

  1. $30,000.00
  2. $60,000.00
  3. $100,000.00
  4. $200,000.00
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CBP's answer: A. A: $30,000.00

Fine Furniture is not a broker and conducted customs business without a license (111.4). For a person who is not a broker, the penalty is not more than $10,000 per transaction and not more than $30,000 in aggregate for all of them (111.91(b)). Ten transactions at $10,000 each would be $100,000, but the aggregate cap is $30,000, so A is right.

In the case of a person who is not a broker, in an amount not to exceed $10,000 for each transaction or violation referred to in § 111.4 and in an amount not to exceed an aggregate of $30,000 for all those transactions or violations. 19 CFR 111.91(b)

Search for: aggregate of $30,000 for all those transactions or violations

CBP's key cites: 19 CFR 111.1; 19 CFR 111.91(a); 19 CFR 111.91(b); 19 CFR 111.4; 19 CFR 111.37; 19 CFR 111.53(c)

Question and key from CBP's October 2026 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).