CustomsBrokerLicenseExam

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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?

  1. 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.
  2. 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.
  3. 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.
  4. 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).