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Entry / Entry Summary · CBLE study guide

Fines, penalties & forfeitures

Section 592, liquidated damages, petitions, seizures, prior disclosure.

Common traps

Wrong answers on past exams cluster around a few beliefs. Here is each one, and what the rule actually says.

Petition and restoration deadlines

“Seizure, penalty and restoration petitions share one deadline.”

The rule: Seizure petitions: 30 days from the seizure notice (171.2(b)). Penalty and LD petitions: 60 days (171.2(b); 172.3(b)). Supplemental petitions: 60 days from the decision (171.61). Restoration of sale proceeds: 3 months after sale (171.42). If under 180 days remain on the statute, at least 7 working days (171.2(e)).

Remember: 30 seizure, 60 penalty/supplemental, 3 months restoration.

19 CFR 171.2 · 19 CFR 172.3 · 19 CFR 171.61 · 19 CFR 171.42

Prior disclosure requirements

“A prior disclosure needs a compliance plan, a loss calculation, or must follow an investigation notice.”

The rule: A valid prior disclosure is made before or without knowledge of a formal investigation. It identifies the merchandise and entries, specifies the false statements or omissions and how and when they occurred, and gives the true information. Missing information is provided within 30 days (extendable). Tender is due at disclosure or within 30 days after CBP's calculation (162.74).

Remember: Disclose, explain, perfect in 30 days, tender.

19 CFR 162.74

Section 592 culpability and penalty ranges

“Fraud starts at 1–4 times the loss, or the levels are confused.”

The rule: Fraud requires clear and convincing evidence of knowing, voluntary, intentional acts. Assessed penalties (commercial cases, Part 171 App. B): fraud 5–8 times the loss of duty (non-duty loss 50–80% of dutiable value); gross negligence 2.5–4 times (25–40%); negligence 0.5–2 times (5–20%); all capped at domestic value. Section 592(d) demands accompany penalty actions.

Remember: Fraud ≥ 5×.

19 CFR Part 171, App. B · 19 CFR 162.73

Challenging an IPR seizure

“Protests or rulings can contest a seizure.”

The rule: Seizures and forfeitures are contested by petition for relief under 19 CFR part 171, not by protest or ruling.

Remember: Seizure → part 171 petition.

19 CFR 171.1

Petition contents

“Petitions must be notarized, in triplicate or name officers.”

The rule: A petition is addressed to the FP&F Officer, need not be in a specific form, and must state the date and place of the violation or seizure, the facts relied on, and be signed (171.1). False statements are punishable under 18 U.S.C. 1001.

Remember: Date, place, facts, signature.

19 CFR 171.1

Who decides supplemental petitions

“The local FP&F officer or broker management decides them.”

The rule: The FP&F Officer reviews first; if unsatisfied, the petition goes to a designated HQ official. Broker (1641) penalties above $10,000 go to the Chief, Penalties Branch, Regulations and Rulings (171.62).

Remember: 1641 > $10,000 → HQ Penalties Branch.

19 CFR 171.62

Try a past question

October 2025 CBLE, question 50

Which regulation lists some of the laws that CBP enforces on behalf of various other federal agencies?

A19 CFR 161.2(a)
B19 CFR 118.4
C19 CFR 141.11(a)(3)
D19 CFR 141.15(c)
Show the answer and why

A. Correct. 19 CFR 161.2(a) lists laws CBP enforces for administering agencies.

B. Incorrect. 118.4 concerns the responsibilities of a centralized examination station operator.

C. Incorrect. 141.11(a)(3) concerns certified duplicate bills of lading.

D. Incorrect. 141.15(c) covers which documents satisfy a bond for production of a bill of lading, not this requirement.

19 CFR 161.2(a) · law as of 2026-11-09

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