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Responsible Supervision & Control

Understanding the broker's duty of responsible supervision under 19 CFR 111.28, the most tested compliance topic.

19 CFR 111.2819 CFR 111.119 CFR 111.2

Core Obligation

19 CFR 111.28 requires that every licensed customs broker exercise responsible supervision and control over the transaction of customs business. This is one of the most fundamental obligations of a customs broker and the most frequently tested topic on the CBLE. The broker must ensure that customs business is conducted with due diligence and accuracy.

What Constitutes Responsible Supervision

Responsible supervision includes: (1) maintaining current knowledge of customs laws and regulations; (2) directly supervising employees who handle customs business; (3) establishing and maintaining written supervisory procedures; (4) ensuring proper classification, valuation, and entry of merchandise; and (5) being available to answer questions from CBP regarding any customs transaction handled by the broker's office.

Consequences of Failure

Failure to exercise responsible supervision and control can result in: suspension or revocation of the broker's license; monetary penalties; and liability for errors made by unsupervised employees. CBP may also impose additional requirements on brokers found to be deficient in their supervisory obligations.

Key Terms

Responsible Supervision|负责监管
Due Diligence|应有的勤勉
Supervisory Procedures|监管程序
License Revocation|执照撤销
Back to Knowledge BaseUpdated 2026-04-09