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HMRC internal manual

Alcohol Wholesaler Registration Scheme

Fit and proper test: due diligence

You must check the business’s due diligence processes to see that they comply with regulatory requirements see AWRS60600. Insufficient due diligence when making decisions on who to trade with increases the risk of duty unpaid products entering legitimate supply chains. It may also be evidence of intent to take part and profit from fraudulent arrangements or, at least, a reckless attitude towards tax obligations. Businesses should already be carrying out due diligence to limit their exposure to the risk of handling duty unpaid goods.

Further information on the due diligence condition is in AWRS60600 and Excise Due Diligence Condition Guidance.