Customs broker due diligence extends to verifying export compliance and informing clients of mandatory certificate requirements.

Customs broker due diligence under the Customs Broker Licensing Regulations requires verifying the correctness of information, advising the client on statutory compliance, and checking the exporter's antecedents and documents. Where the exporter lacked the mandatory Export Inspection Agency certificate when the shipping bills were filed, later procurement did not cure the earlier non-compliance. A plea of ignorance does not reduce the broker's statutory duty, because a customs broker is treated as occupying a position of trust and may be liable for contravention even without intent. The note records that, since revocation of licence and forfeiture of security were not imposed, the penalty was treated as justified.

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Issues: Whether the penalty imposed on the customs broker for failure to exercise due diligence and to inform the exporter of the mandatory Export Inspection Agency certificate requirement was justified.

Analysis: The customs broker's obligations under the Customs Broker Licensing Regulations required due diligence in verifying the correctness of information, advising the client to comply with statutory requirements, and verifying the antecedents and documents of the exporter. The exporter admittedly did not possess the Export Inspection Agency certificate at the time the shipping bills were filed, and the certificate was obtained only later. The plea of ignorance was held insufficient to dilute the statutory duty, and the authority's reliance on the settled principle that a customs broker occupies a position of trust and is liable for contravention even without intent was accepted. The fact that revocation of licence and forfeiture of security were not ordered was treated as sufficient leniency already extended to the appellant.

Conclusion: The penalty was held to be justified and the challenge to the order confirming it failed.

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