No later than _____ calendar days after initiating an investigation under 19 CFR 165.15, CBP will take interim measures if there is _____ that the importer entered covered merchandise into the customs territory of the United States through evasion.
How to get there
This tests two numbers from the EAPA (antidumping/countervailing duty evasion) rules in Part 165: a deadline and an evidentiary standard. Both come from one sentence.
19 CFR 165.24(a): Reasonable suspicionNo later than 90 calendar days after initiating an investigation under § 165.15, CBP will take interim measures if there is a reasonable suspicion that the importer entered covered merchandise into the customs territory of the United States through evasion.
90 days and reasonable suspicion: D.
Why the other choices are wrong
A) 15; substantial evidence and C) 90; substantial evidence: "substantial evidence" is the standard for CBP's final determination at the end of the investigation (§ 165.27(a)), not for interim measures. Interim measures use the lower bar of reasonable suspicion.
B) 15; reasonable suspicion: right standard, wrong deadline. The rule says 90 calendar days.
Trap!
Two standards, two stages: reasonable suspicion triggers interim measures (suspended or extended liquidation, extra security) within 90 days. Substantial evidence supports the final evasion determination. CBP likes to swap them.
Sources: 19 CFR 165.24(a); 165.27(a) (eCFR).
CBP answer key: Answer D · 19 CFR 165.24(a)Source: CBP past exams ↗