19 CFR Part 111: licenses, permits, and responsible supervision and control

Broker compliance is one of the exam categories that rewards knowing where the rule lives, and almost all of it lives in one place: 19 CFR Part 111, “Customs Brokers.” Part 111 is the regulation U.S. Customs and Border Protection (CBP) uses to license brokers, to permit them to do business, and to hold them to a standard of conduct. This guide walks the structure of Part 111 the way the exam tests it: license, permit, responsible supervision and control, and the ongoing obligations that keep a license alive. For the terms used throughout, the glossary defines the core vocabulary, and the corpus map shows where each Part sits.

How is Part 111 organized?

Part 111 is split into subparts, and knowing the map is half the lookup:

Subpart	Sections	What it covers
A: General Provisions	111.1 to 111.5	Definitions
B: Procedure to Obtain License or Permit	111.11 to 111.19	License and permit requirements
C: Duties and Responsibilities	111.21 to 111.45	Recordkeeping, supervision, employee lists, diligence
D: Cancellation, Suspension, Revocation, and Monetary Penalty	111.50 to 111.81	Grounds and proceedings
E: Monetary Penalty and Payment of Fees	111.91 to 111.100	Penalty caps and the fee schedule
F: Continuing Education	111.101 to 111.104	The 36-credit requirement

When a compliance question sends you to “the broker regulations,” it almost always means one of these subparts. Tab them.

What does it take to hold a broker license?

Section 111.11 sets the basic requirements for an individual license. On the date the application is submitted, the applicant must be a citizen of the United States, have attained the age of 21, be of good moral character, and hold a passing grade (75 percent or higher) on an examination taken within the three-year period before the application. The applicant may not be an officer or employee of the United States Government.

A key distinction the exam likes: the requirements to sit the exam are looser than the requirements to hold the license. You can take the test at 18, but you cannot apply for the license until 21. The full path is laid out in how to become a licensed customs broker.

Organizations can be licensed too. Under 111.11, a partnership must have at least one member who is a licensed broker, and an association or corporation must be empowered by its articles to transact customs business and have at least one officer who is a broker.

What is a national permit, and who needs one?

A license lets a person be a broker; a permit lets them actually transact customs business. Section 111.19 establishes the national permit: a single permit required to transact customs business throughout the customs territory of the United States. This modernized framework replaced the older district-by-district permit system, so a broker no longer needs a separate permit for each port.

The permit hinges on supervision. The individual broker who qualifies the national permit must exercise responsible supervision and control over the activities conducted under it. A firm holding a permit therefore has to employ at least one licensed individual who genuinely oversees the customs work. Fees apply: under 111.96 the national permit application fee is $100, and an annual permit user fee is owed each year (set by the fee schedule and published in the Federal Register).

What does “responsible supervision and control” actually mean?

This is the most heavily tested concept in broker compliance, and it is deliberately a standard, not a checklist. Section 111.1 defines responsible supervision and control as the degree of supervision and control necessary to ensure the proper transaction of the broker’s customs business, including the actions necessary to ensure that an employee provides substantially the same quality of service in handling customs transactions that the broker is required to provide.

Section 111.28 fleshes it out with the factors CBP weighs, which is where wrong answers hide. They include:

• The number of licensed brokers employed relative to the volume and complexity of the work.
• Training of employees and issuance of written instructions and guidelines.
• The volume and type of business handled, and the reject rate on entries.
• Whether employees have access to current editions of the regulations.
• The frequency of audits and reviews, and the timeliness of entry filing and duty payment.

Section 111.28 also requires the broker to keep CBP informed about its people. Before receiving a national permit, and then on an ongoing basis, the broker must submit a list of employees (names, and identifying details such as dates and places of birth, hire dates, and current addresses), and must report changes, new hires, and terminations to CBP within 30 days.

What ongoing obligations keep a license alive?

Getting licensed is not the end of Part 111. Two recurring duties matter most:

The triennial status report. Under 111.30, every individual broker must file a status report and pay a $100 fee during the period beginning February 1 of each third year (the framework dates from 1985). The report is due by March 1; if it is not filed, the license is suspended by operation of law on that date, and if it is still not cured, the license is revoked by operation of law without prejudice to applying for a new one. The same section requires prompt notice of changes to a broker’s address, business name, or organization.

Continuing education. Subpart F (111.101 to 111.104) requires each individual broker subject to the rule to complete at least 36 continuing education credits per triennial period and to report and certify that completion. Failure to comply is itself a ground for administrative action.

What conduct can cost a broker the license?

Subpart D lists the grounds. Section 111.53 lets CBP cancel, suspend, or revoke a license or permit, or impose a monetary penalty, when a broker:

• Made a false or misleading statement of material fact in an application or report.
• Was convicted of a felony or of a misdemeanor involving importation, customs business, or dishonesty such as theft, forgery, or embezzlement.
• Violated any law enforced by CBP or its regulations.
• Counseled, induced, procured, or knowingly aided and abetted another person’s violation.
• Knowingly employed a convicted felon in the customs business without written approval.
• With intent to defraud, willfully deceived, misled, or threatened a client.
• Was convicted of, or conspired to commit, an act of terrorism.

The penalty side lives in Subpart E: under 111.91 the monetary penalty against a broker may not exceed an aggregate of $30,000 for the covered grounds. How those penalties are assessed and mitigated is the subject of the customs penalties and prior disclosure guide.

Practicing broker compliance for the exam

Compliance questions are lookup questions: they name a duty and ask which rule governs, or hand you a fact pattern and ask whether the broker met the standard. The fastest candidates know that “who may hold a license” is 111.11, “the permit” is 111.19, “supervision” is 111.28, and “grounds to lose the license” is 111.53. Drill that map in the navigation trainer, see how Part 111 sits beside recordkeeping and entry in the corpus map, and test recall with the free practice test. For how compliance fits the whole exam, start with the customs broker exam guide.

Sources: 19 CFR Part 111 (Customs Brokers), sections 111.1, 111.11, 111.19, 111.28, 111.30, 111.53, 111.91, 111.96, and Subpart F, as published on the Legal Information Institute mirror of the Code of Federal Regulations (law.cornell.edu/cfr/text/19), cross-checked against the eCFR (ecfr.gov/current/title-19), reviewed 2026-07-24. Regulations and fees change; confirm the current text against the eCFR before relying on it.