Duty to exercise due diligence: strict licensing compliance can justify administrative revocation and security forfeiture for brokers.
The headnote focuses on the duty of diligence under the CBLR 2018, identifying failures to advise clients, to verify information, and to supervise employees as breaches that can attract administrative penalties against a customs broker's licence. It also confirms that regulatory action may be initiated at the broker's registered location regardless of where the underlying transactions occurred, and highlights the need for compliance programs, client advisory practices, and employee training.