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Resources for Customs Brokers

Resources on Enforcement:

The government maintains several legal mechanisms for enforcement against CHBs, including:

  • Brokerage Audits

  • License revocation proceedings

  • Broker penalties ($30,000 liability per occurrence)

  • Negligence/fraud claims under Trek Leather (19 U.S.C. 1592)

  • Criminal concerning false statements, and etc.

In addition, various types of liability may exist to private parties, such as importers and exporters, or other members of the supply chain.

If your company is the target of enforcement action, we strongly advise that you contact a member of the firm to discuss your matter.



December 5, 2018: CBP: H290002: CHBs can’t pay unlicensed sales people on a commission basis.

November 21, 2018: CBP: LBG Guidance on Annual User Fees for Permits (due January 25, 2019).

November 15, 2018: Am. Shipper: FMC declines to intervene in S. California PierPass Program.

November 9, 2018: NY/NJ 19-00-NWK Pipeline: Validating POAs.

October 24, 2018: CBP: Response to the Senate Committee on Finance, re: CBP iniatives.

October 19, 2018: A Georgia state court decision holds that an IOR claims against a CHB are limited to contractual remedies prescribed in terms & conditions of a POA, thereby contravening an action for negligence. It’s unclear whether issues of fiduciary duty, or a breach of the warranty of good faith and fair dealing were ever at issue.

January 10, 2018: CBP Video: Unified Cargo Processing (UCP).