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HMRC internal manual

Alcohol Wholesaler Registration Scheme

Penalties and sanctions: trading without approval - types of penalty

There are three types of contravention:

  • deliberate and concealed,
  • deliberate but not concealed, or
  • any other case (referred to in this guidance as non-deliberate).

Penalties for trading without approval are designed to address the behaviour that caused the contravention. The more serious the behaviour, the higher the possible penalty will be.

Within the deliberate category, the law provides for higher penalties in the most serious cases where the person has not merely failed to apply for approval, but has also taken steps to conceal the contravention.