Broker Compliance · CBLE study guide
Broker discipline & penalties
Suspension, revocation, monetary penalties and mitigation for brokers.
- 37past questions in CBLE Pass
- ≈4questions on a typical 80-question exam
- 19 CFR 111.53-111.92, Part 171 App. Cwhere the rules live
Common traps
Wrong answers on past exams cluster around a few beliefs. Here is each one, and what the rule actually says.
Broker penalty ceiling per notice
“A broker penalty notice can exceed $30,000.”
The rule: A broker may be penalized a maximum of $30,000 for any violation or violations of 19 U.S.C. 1641 in one penalty notice.
Remember: $30,000 per notice; repeat conduct leads to suspension or revocation.
19 CFR Part 171, App. C, sec. XII.A
Continuing education: who and what records
“Organizational brokers also certify CE, or CE records must include the date proof was received.”
The rule: Only individual brokers must complete and certify CE (36 credits per triennial period), keeping title, provider, dates attended, credits, location, and provider documentation for 3 years after the status report. Records must be produced within 30 calendar days of receipt of CBP's request.
Remember: CE is personal to individual brokers; keep records 3 years after the report.
19 CFR 111.101 · 19 CFR 111.102
Felon-employment penalty tiers
“Any felon-employment violation is $5,000, or always $30,000 with revocation.”
The rule: $5,000: approval not sought within 30 days of discovering the conviction. $25,000: knowingly employing a felon without seeking approval. $30,000: continuing after approval is denied.
Remember: Knew at hire and never asked = $25,000.
19 CFR Part 171, App. C, sec. VII
Offer in compromise deposit
“A partial deposit or a fixed minimum accompanies an offer in compromise.”
The rule: The offer must be in writing to the Commissioner, and CBP will not consider it until the specific sum offered has been deposited.
Remember: Offer in writing + deposit the full amount offered.
19 CFR 161.5
Short petition period near the statute of limitations
“The minimum shortened petition period is 10 business days, 30 working days, or 7 calendar days.”
The rule: When fewer than 180 days remain before the statute of limitations, the FP&F Officer may set a shorter petition period, but not less than 7 working days.
Remember: 7 working days (not calendar days).
19 CFR 171.2(e)
Mitigation decisions are not protestable
“A mitigation decision can be protested within 180 or 365 days.”
The rule: Decisions to remit or mitigate a penalty or cancel liquidated damages upon payment of a lesser amount are not protestable decisions under 19 U.S.C. 1514.
Remember: Penalties/LDs: petitions, not protests.
19 CFR 172.22(a)
Try a past question
October 2026 CBLE, question 10
Which ONE of the following actions is NOT grounds for the suspension or revocation of a broker's license?
Show the answer and why
A. A ground. A false or misleading statement in a license application is listed (19 CFR 111.53(a)).
B. A ground. A felony conviction involving embezzlement is listed (19 CFR 111.53(b)(3)).
C. Correct (NOT a ground). A broker may transact business for a bona fide importer whose broker license was cancelled with prejudice (19 CFR 111.42(b)).
D. A ground. Knowingly employing a felon without approval is listed (19 CFR 111.53(e)).
19 CFR 111.53 · 19 CFR 111.42(b) · law as of 2026-11-09
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