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October 2026, question 3
Broker Compliance · Broker licensing and duties
Licensed customs broker Dennis Parker was the corporate license qualifier and sole qualifying officer for Owl B There Logistics (Owl B) until his employment was terminated six months ago. Mr. Parker immediately provided written notice to CBP of his termination, but Owl B has not yet identified a new qualifying officer. Over the past six months, Owl B has continued to transact customs business on behalf of clients. Based on this scenario, which ONE of the following statements is FALSE?
- Owl B has demonstrated grounds for the suspension or revocation of its corporate license under 19 CFR 111.53(h). CBP may revoke Owl B's license and national permit by operation of law.
- Owl B is liable for a monetary penalty for each transaction of customs business conducted after Mr. Parker’s termination, not to exceed an aggregate of $10,000.00 for all transactions.
- Mr. Parker fulfilled his responsibility to CBP as an individually licensed broker and is not liable for violations made by Owl B after his termination.
- In addition to transacting customs business without a qualifying officer, Owl B also failed to provide CBP with timely notification of a change in its organization.
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CBP's answer: B. B: Owl B is liable for a monetary penalty for each transaction of customs business conducted after Mr. Parker’s termination, not to exceed an aggregate of $10,000.00 for all transactions.
The question asks for the FALSE statement. Section 111.91(b) caps the penalty for transacting customs business without a license at $10,000 per transaction and an aggregate of $30,000 for all transactions, so B, which says a $10,000 aggregate, is false. A is supported by 111.53(h), which makes failing to meet the 111.11 and 111.19 requirements a ground for suspension or revocation, and C and D follow from Mr. Parker's immediate notice under 111.28(d) and Owl B's lack of a qualifying officer.
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)
The broker no longer meets the applicable requirements of §§ 111.11 and 111.19. 19 CFR 111.53(h)
Search for: aggregate of $30,000 for all those transactions or violations
CBP's key cites: 19 CFR 111.4; 19 CFR 111.91(b)
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).