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HMRC internal manual

Alcohol Wholesaler Registration Scheme

Penalties and Sanction: Buying from an unapproved wholesaler - Deliberate but not concealed

Buying from an unapproved wholesaler is deliberate but not concealed if the person:

  • knows or has reasonable grounds to suspect that the wholesaler is unapproved, and
  • purchases from them regardless, but
  • does not take steps to conceal his deliberate failure

Example of Deliberate but not Concealed action

Adam owns a restaurant. His restaurant has an unexpected busy night and he runs out of a popular brand of wine. In a hurry he calls a late night alcohol delivery business who agree to deliver the wine immediately. Adam does not check the AWRS status of the business and it turns out that the wholesaler has never applied for AWRS approval and is operating illegally. Adam later realises that the wholesaler is not approved and informs HMRC providing details of the transaction.