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HMRC internal manual

Alcohol Wholesaler Registration Scheme

Penalties and Sanctions : Buying from an unapproved wholesaler overview

The AWRS is designed to prevent illicit trading in the wholesale sector. From 1 April 2017, it is an offence to buy controlled liquor that is intended for re-sale from unapproved UK wholesalers (except for excluded sales).

From 1 April 2017, any person who contravenes this requirement can be guilty of a criminal offence or subject to a penalty. A trader is not liable to a civil behavioural penalty if they have also been convicted of a criminal offence for the same contravention.

For guidance on Trade Buyer Obligations see AWRS90200

We will not charge a penalty if we are satisfied that a person (P):

  • Has a reasonable excuse for a non-deliberate failure, and
  • If the excuse has ended, P has remedied that failure without unreasonable delay

We must assess the value of the penalty. The amount is based on a maximum penalty value of £10,000 but the actual amount will be determined by the behaviour that caused the contravention - higher penalties (not exceeding £10,000) are payable if the contravention was deliberate. 

For detailed guidance on how to calculate the penalty please refer to AWRS110000

Reductions in the percentage penalty are given for disclosure and depend upon

  • whether the disclosure is unprompted or prompted, and
  • the quality of the disclosure.

We may agree to a special reduction of the penalty if there are special circumstances. You can find more details in AWRS110500.  Suspension of penalties is not applicable to AWRS behavioural penalties.