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HMRC internal manual

Alcohol Wholesaler Registration Scheme

Penalties and sanctions: Buying from an unapproved wholesaler - deliberate and concealed

Buying from an unapproved wholesaler is deliberate and concealed if the person:

  • knows or had reasonable grounds to suspect that the wholesaler was unapproved, but
  • purchased from them regardless, and
  • took steps to conceal the fact that they did so.


HMRC have a criminal investigation policy (link is external) and will refer the most serious cases for consideration of criminal proceedings where appropriate.

The act of concealment may include:

  • Destroying books or records which show evidence of wholesale purchases from unapproved wholesalers so that they should not be available
  • Falsifying records so that it appears the purchases were from approved wholesalers
  • Providing invoices from approved wholesalers to account for alcohol purchased from unapproved wholesalers
  • Concealing the use of premises or storage facilities used to sell or store alcohol from unapproved wholesalers


Example of Deliberate and Concealed:

Sally runs a corner shop struggling to compete with a newly opened 24h convenience store. She buys most of the alcohol she sells from a large dependable AWRS approved wholesaler.  A recent cold caller offered to undercut the best trade deal she could get, on the brands she sells, by a good margin.  She made cash in hand purchases from that person on several occasions. No invoices are provided and none are requested. 

On a routine HMRC visit Sally is asked to provide a copy of her purchase records for stock on hand, she provides the records from her normal regular supplier.  A verification of the stock on hand show that it came from two sources, that the invoices Sally provided did not relate to all of her stock.  Also a cash reconciliation indicated that more stock had passed through the businesses than purchase records showed she had purchased. Sally was aware of the requirement to only purchase alcohol from approved wholesalers and deliberately chose not to.  She also took steps to conceal the purchase.

Reasonable excuse is not available for deliberate and concealed behaviour.