Category Archives: Nuts & Bolts

CBLE Info

If you are scheduled to take the CBLE (Customs Broker License Exam) on October 26th make sure to check if your test site has a vaccine or mask mandate. Here is the notice from the CBP website.

https://www.cbp.gov/trade/programs-administration/customs-brokers/license-examination-notice-examination

NOTICE: Given the evolving COVID-19 situation examinees are responsible for checking the PDRI/PSI COVID-19 page (https://www.psionline.com/important-notice-update-concerning-covid-19-c…) regularly to find out if there is a vaccine or mask mandate at the registered testing site. It is THE EXAMINEE’S responsibility to stay up to date. CBP will NOT provide refunds for those who are not able to test as a result of being uninformed or noncompliant about the COVID-19 policy. CBP and PDRI/PSI recommend that the examinee checks the website regularly leading up to the exam, including the night before the CBLE.

Best of luck!

Paper ECPs

Last week’s post described common roadblocks to establishing Export Compliance Programs. In some cases exporters may be under pressure to put a program in place quickly with the focus on creating the ECP manual. This approach ignores the foundation needed for an effective program. The likely result will be a glossy manual that will sit on the shelf and have little impact on operations.

Compliance professionals know that an effective ECP must include C- level commitment and involvement, sufficient funding, well defined and documented responsibilities, on-going training, and internal audits. Weak ECPs lack some of these elements and are simply window dressing or paper programs.

In house compliance professionals are often given responsibility without authority. Further, they may be at mid or lower management levels or in the wrong chain of command. With or without a formal ECP, compliance professionals must have the authority to place holds on questionable exports without being overruled by sales, finance, or supply chain. Well written protocols for resolving issues and releasing holds require C-level or legal approval.

All of the above illustrates the importance of compliance independence. This may mean reporting to the CEO, COO, or legal department in order to remove pressure from other groups.

If your in house compliance professional is not truly independent hire a consultant!

Contact mitch@adhoclogistics.com for immediate assistance.

LinkedIn Comment- CBLE Pass Rates

Pete Mento

I’ve never steered clear of controversy – so, a serious question. Why is it that people do not want to become Customs Brokers anymore? Maybe its the silly test? Only around 2400 people take the exam every year, with around 10-20% passing.

Mitch Kostoulakos, LCB Ad Hoc Logistics LLC, Licensed Customs Broker, International Logistics Consultant

Do any other licensing exams have such low pass rates? Bar exam rates are much higher. I’m in favor of an exam with realistic chance of passing along with a continuing education requirement for brokers.

Got a Question?

Anyone who has ever taken the CBLE (Customs Broker License Exam) knows that it is very challenging. Many of the questions seem obscure even to experienced brokers. Here is an opportunity to submit questions for future exams.

CBP welcomes the submittal of new questions for future broker exams.  Please submit your questions to brokermanagement@cbp.dhs.gov with “Future Exam Questions” in the subject line. 

Select HERE for the Guidelines on writing new questions.

https://www.cbp.gov/document/guidance/customs-broker-examination-guidelines-writing-new-questions

Look Inside

You may be looking to add a logistics or compliance pro to your staff and, understandably, want to make a good selection. In the meantime let me suggest training your shippers in some export compliance basics. I have always warned that compliance should not be left to a busy shipping department. However, a few hours of training is a good investment as it will enable shippers to spot possible export violations before shipments leave your dock. It will also allow your new professional to focus on more strategic matters and hit the ground running.

Ad Hoc Logistics has several copyrighted training programs to get you started. Contact mitch@adhoclogistics.com for info.

A to Z of Managing Logistics

Exporting for Smart People ( Because You’re No Dummy)

Red Flag Screening for Exports

LinkedIn Comment- LCB Revocations

Jim Dickeson – Trade Compliance Geek• 🌏 Global trade is my passion | Trade compliance is my game | Chocolate is my weakness1d •

Anybody you know? Did you file your last triennial status report? It’s one way to get your name in the Federal Register. I know several on this list, but I believe they’ve all retired.

https://www.federalregister.gov/documents/2022/08/24/2022-18213/notice-of-revocation-of-customs-brokers-licenses

Mitch Kostoulakos, LCB Ad Hoc Logistics LLC, Licensed Customs Broker, International Logistics Consultant

Checking the list is a good idea. The license is not easy to obtain so need to protect it. Surprised at the number of revocations.

Unmanaged Logistics

From the archives:

Many of my clients are hard-working owners or operators of small businesses. They don’t have in-house compliance or logistics expertise so must wear several hats. Day to day activities or unexpected issues take up most working hours. As a result, functions such as logistics planning and import/export compliance are often unmanaged or left entirely to LSPs (Logistics Service Providers).

Making sure that your business is in compliance with import and export regulations is good risk management as well as good business. Think of it as insurance. A few basic steps can make a big difference and can be implemented quickly.

Ad Hoc Logistics can provide step by step guidelines, train your employees, and set up sustainable procedures. Recent consultations included our copyrighted programs:

Exporting for Smart People- Because You’re No Dummy

Red Flag Screening

A to Z of Managing Logistics

Contact mitch@adhoclogistics.com for a no obligation discussion.

LinkedIn Comment- LCB value

Mitch Kostoulakos, LCB commented on this

Nadeem Virk, LCB• 2ndUsing Trade Compliance to Help You Grow | Licensed Customs Broker (LCB) | Founder and CEO @ VTC5h • 

If you have a couple of year’s worth of trade compliance experience, that LCB designation isn’t going to boost you up that much.

Mitch Kostoulakos, LCB Ad Hoc Logistics LLC, Licensed Customs Broker, International Logistics Consultant

Curious post. As an LCB you know how difficult it is to obtain the license. Why de-value the accomplishment?