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HMRC internal manual

Alcohol Wholesaler Registration Scheme

Regulatory penalties: applying penalties - making the decision to apply a penalty

If you visit a wholesaler who has not complied with the requirements of the scheme, you should ask yourself the following:

  • Is the contravention liable to a fixed regulatory penalty?
  • Is the contravention a first breach? If so, you should consider whether a warning letter is appropriate.
  • Has the wholesaler got a reasonable excuse? See ECP8000 for further details of reasonable excuses.
  • Would the issue of a civil penalty have a greater compliance effect than other possible action?