April 2019 — Question 53

CBP is conducting a broker audit of Interstate Dynamic Logistics CHB based upon evidence of improper use of HTSUS classification. During the audit, they request copies of Powers of Attorney (POAs) for entries related to four different Importer clients. Interstate Dynamic Logistics CHB is unable to provide the Power of Attorney for one of the three Importer Clients, one of the other POAs is not signed by the Importer Clients Guarantor, the third POA is not dated, and the guarantor on the fourth POA is on the U.S. Governments restricted persons list. What action can CBP take?

• AA warning/penalty for conducting customs business for a client without a POA.✓ CBP's answer
• BSuspension of the broker’s electronic filing privilege until two of the POAs are brought into compliance.
• CA $10,000 penalty for conducting customs business without a permit.
• DImmediate revocation of Customs Broker License for conducting customs business without having proper POAs.
• EA $10,000 recordkeeping penalty.