CustomsBrokerLicenseExam

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October 2026, question 4

Broker Compliance · Broker licensing and duties

A corporate customs broker, Global Trade Solutions Inc. (Global), employs multiple licensed customs brokers (LCBs), some of whom are corporate officers and some of whom are employees. Global's responsible supervision and control plan designates a specific LCB as the broker of record for each client account. One of Global’s LCB employees, Julia Pryne, has been on extended leave for several months. During this time, an unlicensed employee who normally works under Ms. Pryne’s supervision has been signing customs entry documents and communicating directly with CBP on behalf of Ms. Pryne’s client, without Ms. Pryne’s knowledge or guidance. Global’s corporate officers and other LCB employees are aware of the situation but do not intervene. If CBP determines this scenario constitutes a breach of responsible supervision and control, who is accountable for the breach?

  1. Julia Pryne
  2. Julia Pryne’s unlicensed employee
  3. Every licensed officer of Global Trade Solutions Inc.
  4. All licensed officers and licensed employees of Global Trade Solutions Inc.
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CBP's answer: C. C: Every licensed officer of Global Trade Solutions Inc.

Section 111.28(a) puts responsible supervision and control on every licensed officer of a corporation broker, not just on the employee assigned to the client account. When the corporation's licensed officers knew of the unlicensed employee signing documents and did nothing, each of them is accountable, so C is right. Julia Pryne was on leave without knowledge, the unlicensed employee is not the party that owes the duty, and licensed employees who are not officers are not named in 111.28(a).

every licensed officer of an association or corporation that is a broker must exercise responsible supervision and control 19 CFR 111.28(a)

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CBP's key cites: 19 CFR 111.1; 19 CFR 111.28(a)

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).