Forty-two days ago, a customs broker knowingly hired a person convicted of a felony. At no point has the customs broker sought approval for this hire from CBP. Additionally, CBP is not aware of this hire. As of today, what is the heaviest single maximum penalty that can be assessed by CBP against this broker for not seeking approval from the appropriate Executive Director, Office of Trade for the felon's continued employment?
$25,000. The broker penalty guidelines in 19 CFR Part 171, Appendix C, section VII set a $25,000 penalty for knowingly employing a convicted felon without seeking approval for the employment (paragraph C). The $5,000 penalty (paragraph B) is for a broker who does apply, but only after the 30-day window. The $30,000 penalty, with revocation or suspension generally appropriate, is for continuing to employ the felon after approval has been denied (paragraph D). Here 42 days have passed, the broker never applied, and no approval has been denied, so paragraph C is the heaviest penalty available. Source: 19 CFR Part 171, Appendix C, section VII, paragraphs A-D (2023 ed.; unchanged in eCFR as at 7 Oct 2026). CBP answer key: C. CBP's citation: 19 CFR 171, Appendix C, VII(C).
Jumping to $30,000 and revocation; that tier needs an application that CBP has denied, and here none was made.
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