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Broker Compliance

October 2019 — Question 9

If the commercial invoice is in a foreign currency, the foreign currency shall be converted to U.S. dollars using the proclaimed rate or certified rate or rates effective on the_______ .

Why this answer

Currency conversion for customs purposes is governed by the subpart CBP cited, and it fixes the date of exportation as controlling: a commercial invoice in foreign currency is converted to U.S. dollars at the proclaimed or certified rate effective on the date the merchandise was exported to the United States. None of the later milestones in the import timeline — importation, release, or payment of duties, taxes, and fees — plays any role, and the invoice date matters only as possible evidence of when exportation occurred. The date of importation is the tempting distractor because it feels like the moment customs obligations attach, but the rule says exportation. Watch for: Converting currency as of the importation date rather than the exportation date.

Original CBLE Simulator explanation — the question and key above are CBP's; this analysis is ours. Verify against the current edition before relying on it in practice.

CBP's cited authority

§ 19 CFR 159.32

Answer and citations as published in CBP's official answer key for the October 2019 examination.

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