CBLE Broker Duties, Supervision, Records & Penalties question: files on a cloud server located in Canada and keeps

CBLEBroker Duties, Supervision, Records & Penalties

A brokerage stores its client files on a cloud server located in Canada and keeps no copy in the United States. What does Part 111 say?

A Only paper records, not electronic ones, must be kept in the US
B Electronic records may be kept anywhere if CBP can reach them online
C Its original records must be kept in the US customs territory
D Records may be kept abroad if the broker notifies the processing Center

Show the answer and explanation

Answer: C. Its original records must be kept in the US customs territory

19 CFR 111.23(a) requires a licensed customs broker to maintain originals of the records referred to in Part 111, including records stored in electronic formats, within the customs territory of the United States, in line with Part 163. A server outside the customs territory does not meet the rule, whether or not CBP has remote access. This requirement was added in the 2022 modernization. Source: 19 CFR 111.23(a) (eCFR, as at 7 Oct 2026); CBP Customs Broker Regulations page.

Common mistake

Assuming electronic records are exempt from the location rule.

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Original study material mapped to the public CBP exam categories; not a real test question.Independent. Not affiliated with or endorsed by U.S. Customs and Border Protection (CBP). Verify figures and rules against current guidance before relying on them.