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HMRC internal manual

Alcohol Wholesaler Registration Scheme

Penalties and sanctions: what does not count as trading without approval?

At application stage, a wholesaler is required to inform us of all of their trading premises for approval of those premises. They are also required to notify any changes to those premises including the addition of new trading premises. This is so a wholesaler cannot carry on an illicit wholesale business from undisclosed premises using a legitimate business as a cover.

However, the requirement to notify these details is a requirement under the Wholesaling of Controlled Liquor Regulations 2015. If you find an approved business has started trading from new premises or failed to inform us of trading premises when they applied for approval, this is not ‘trading without approval’ but a breach of the regulations. This failure would incur a regulatory penalty of £500 for failure to comply with a regulatory requirement.  The guidance on regulatory penalties is contained in AWRS140000

Depending on the circumstances, you may want to consider whether the failure affects the business’s fit and proper status. This is covered in more detail in AWRS50000.