19 CFR Part 133 · 8 questions
19 CFR 133.27 — Civil fines for those involved in the importation of merchandise bearing a counterfeit mark.
Past customs broker license exam questions whose answer rests on 19 CFR 133.27. Drawn from 8 released sittings, April 2023 through October 2025. Every question below is a real released question with the answer CBP credited, the authority it rests on, and an explanation of why that answer is right.
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April 2023, Q10. What is the civil fine for a first violation under 19 U.S.C. 1526(f) and 19 CFR 133.27 on any person who directs, assists financially or otherwise, or aids and abets the importation of merchandise for sale or public distribution that bears a counterfeit mark resulting in a seizure of the merchandise?
- AThe fine imposed will not be more than the value the merchandise would have had if it were genuine, according to importer’s selling price in the United States of similar merchandise.
- BThe fine imposed will not be more than the value the merchandise would have had if it were genuine, according to the manufacturer’s suggested retail price in the United States at the time of seizure.
- CThe fine imposed will not be more than two times the value the merchandise would have had if it were genuine, according to the manufacturer’s suggested retail price in the United States at the time of seizure.
- DThe fine imposed will not be more than three times the value the merchandise would have had if it were genuine, according to the manufacturer’s suggested retail price in the United States at the time of seizure.
- EFines are only imposed on the second and each subsequent seizure and never on a first seizure.
Show the answer and explanation
The correct answer is B because 19 CFR 133.27(a) explicitly states that for a first violation, the fine cannot exceed the value of the merchandise if genuine, based on the manufacturer’s suggested retail price at the time of seizure. Options A and C/D are incorrect because they reference the importer’s selling price or multiples of the value, which are not specified in the cited regulation. Option E is wrong because the regulation clearly imposes fines for first violations, not only subsequent ones.
April 2026, Q8. What is the maximum civil fine CBP may impose after the seizure of merchandise imported for sale when the merchandise is seized pursuant to 19 USC 1526(e) for bearing a counterfeit mark, has a domestic value of $1,000, and would have a manufacturer’s suggested retail price (MSRP) of $25,000 in the United States at the time of seizure if it had been genuine?
- A$1,000 if this seizure is the importer’s first seizure under 19 USC 1526(e)
- B$1,000 if this seizure is the importer’s second seizure under 19 USC 1526(e)
- C$25,000 if this seizure is the importer’s first seizure under 19 USC 1526(e)
- D$25,000 if this seizure is the importer’s second seizure under 19 USC 1526(e)
Show the answer and explanation
The correct answer is C because 19 CFR 133.27(a) specifies that for the first seizure under 19 USC 1526(e), the maximum civil fine is the merchandise’s manufacturer’s suggested retail price (MSRP) if it were genuine, which is 25,000 here. Options A and B incorrectly use the domestic value of 1,000, which is irrelevant to the fine calculation under this regulation. Option D incorrectly applies the second-seizure rule (which would impose twice the MSRP, i.e., 50,000) but states the wrong amount (25,000) for a second violation. The authority explicitly ties the fine to the MSRP, not the domestic value, and distinguishes between first and subsequent violations.
October 2019, Q68. The assessed amount of a penalty issued under 19 U.S.C. 1526(f) for a seizure taken under 19 U.S.C. 1526(e) is derived from:
- ADomestic Value
- BManufactured Suggested Retail Price Value
- CDutiable Value
- DForeign Value
- ETransaction Value
Show the answer and explanation
The correct answer is B because 19 CFR 133.27 explicitly states that the penalty under 19 U.S.C. 1526(f) is calculated based on the "manufacturer's suggested retail price in the United States at the time of seizure," which directly corresponds to the "Manufactured Suggested Retail Price Value." Other options like domestic value, dutiable value, foreign value, or transaction value are not mentioned in the cited authority and are irrelevant to this specific penalty calculation. The regulation does not reference any alternative valuation method for this context.
October 2020 (AM), Q58. In addition to seizure of the merchandise, CBP may impose a civil fine on a person who directs, assists financially or otherwise, or aids and abets the importation of merchandise for sale or public distribution that bears a counterfeit mark. What is the highest amount of a civil fine for a first-time seizure of importing merchandise with a counterfeit mark?
- ATwice the Value of the Merchandise
- B$10,000
- C$100,000
- DManufacturer’s Suggested Retail Price of Genuine Article
- ENo monetary civil fine
Show the answer and explanation
The correct answer is D because 19 CFR 133.27(a) explicitly states that for a first-time seizure, the civil fine cannot exceed the value of the merchandise if it were genuine, measured by the manufacturer’s suggested retail price in the U.S. at the time of seizure. Option A is incorrect because "twice the value" applies only to subsequent violations under 19 CFR 133.27(b). Options B and C are not mentioned in the cited regulation, which instead ties the fine to the retail price of the genuine article. Option E is wrong because the regulation clearly permits a civil fine, albeit limited to the specified value.
October 2020 (PM), Q59. In addition to seizure of the merchandise, CBP may impose a civil fine on a person responsible for the importation of merchandise bearing a counterfeit mark. What is the highest amount of a civil fine for a first-time violation of importing merchandise with a counterfeit mark?
- ATwice the value of the merchandise
- B$10,000
- C$100,000
- DManufacturer’s Suggested Retail Price of Genuine Article
- ENo monetary civil fine
Show the answer and explanation
The correct answer is D because 19 CFR 133.27(a) explicitly states that for a first violation, the civil fine cannot exceed the value of the merchandise if it were genuine, as determined by the manufacturer’s suggested retail price at the time of seizure. Option A refers to "twice the value," which applies only to subsequent violations under 19 CFR 133.27(b), not first-time offenses. Options B and C are not mentioned in the cited regulation, and E is incorrect because the text confirms a fine is imposed, albeit based on the retail price of the genuine article.
October 2022, Q58. Importer Y operates a discount jewelry store and advises Broker A that it has a shipment of Rolex Submariner watches arriving from Vietnam. Importer Y asks Broker A to clear the shipment of watches. The shipment is detained and seized by CBP after an inspection revealed that the watches were counterfeit merchandise. The commercial invoice from the vendor in Vietnam indicates that the ten (10) Rolex Submariner watches were sold to Importer Y for $10,000.00. The manufacturer’s suggested retail price (MSRP) of one genuine Rolex Submariner is $19,250.00. Importer Y previously had a shipment of counterfeit NFL Superbowl rings seized and forfeited by CBP. Importer Y receives a notice and demand for a civil fine and consults with Broker A. What is the maximum civil fine amount that could be sought by CBP under these facts? .
- AThe maximum civil fine is $10,000.00.
- BThe maximum civil fine is $19,250.00.
- CThe maximum civil fine is $20,000.00.
- DThe maximum civil fine is $38,500.00.
- EThe maximum civil fine is $385,000.00.
Show the answer and explanation
The correct answer is E because the importer has a prior seizure (counterfeit NFL rings), making this a subsequent violation under 19 CFR 133.27(b), which allows a fine up to twice the MSRP. The MSRP for one genuine Rolex Submariner is 19,250, so 10 watches would be 10 × 19,250 = 192,500. Doubling this for a subsequent violation yields 385,000. Options A and B incorrectly use the invoice value or MSRP without accounting for the prior violation. Option C is a distractor with an arbitrary figure. Option D incorrectly doubles the invoice value instead of the MSRP.
October 2023, Q66. For a first violation, from which value will CBP derive the assessed amount of a civil fine under 19 U.S.C. 1526(f) against any person who directs, assists financially or otherwise, or aids and abets the importation of merchandise for sale or public distribution that bears a counterfeit mark resulting in a seizure of the merchandise?
- AManufacturer's suggested retail price in the U.S. if genuine
- BFair retail value in the country of shipment
- CForeign shipper's suggested retail price of the merchandise as imported
- DTransaction value as determined under 19 CFR 152.103.
Show the answer and explanation
The correct answer is A because 19 CFR 133.27(a) explicitly states that for a first violation, the fine is based on the "manufacturer's suggested retail price in the United States at the time of seizure," which aligns with option A. Option B is incorrect because the regulation does not reference "fair retail value" in the country of shipment; it focuses on U.S. retail pricing. Option C is incorrect as the authority does not mention the foreign shipper’s suggested retail price. Option D is incorrect because transaction value under 19 CFR 152.103 pertains to customs valuation for duties, not the civil fine calculation under 19 U.S.C. 1526(f).
October 2025, Q59. For a first violation, Customs and Border Protection may impose a civil fine on any person who directs, assists financially or otherwise, or aids and abets the importation of merchandise seized for bearing counterfeit marks in the amount of:
- ANot more than the domestic value of the imported merchandise at the time of seizure.
- BNot more than the value of the merchandise had it been genuine, according to the manufacturer's suggested retail price in the United States at the time of seizure.
- CNot more than twice the domestic value of the imported merchandise at the time of seizure.
- DNot more than twice the value the merchandise had it been genuine, according to the manufacturer's suggested retail price in the United States at the time of seizure.
Show the answer and explanation
The correct answer is B because 19 CFR 133.27(a) explicitly states that for a first violation, the fine cannot exceed the value the merchandise would have had if genuine, based on the manufacturer's suggested retail price at the time of seizure. Options A and C reference "domestic value," which is not mentioned in the authority text, and D applies the "twice" multiplier, which is reserved for subsequent violations under 19 CFR 133.27(b), not first violations. The authority text does not support any other valuation method or multiplier for first offenses.
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Start practising freeOther sections of Part 133 the exam tests
- 19 CFR 133.21 (15 questions)
- 19 CFR 133.3 (5 questions)
- 19 CFR 133.2 (5 questions)