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HMRC internal manual

Alcohol Wholesaler Registration Scheme

Variations and conditions: due diligence condition

It is a condition of approval that approved wholesalers undertake reasonable, appropriate due diligence checks on their supply chains and have robust procedures to reduce risks of trading in illicit goods.

The fraud risks within a supply chain are unique to each business. You should check to ensure wholesalers have objectively assessed the risks of alcohol duty fraud within the supply chains in which they operate and have put in place reasonable and proportionate checks in their day to day trading to identify transactions that may lead to fraud or involve goods on which duty may have been evaded. They must have procedures in place to take effective mitigating action where a risk of fraud is identified and document the governance they have in place to ensure that these are carried out as intended.

Further guidance is available in the AWRS Excise Notice 2002 and in the Excise Due Diligence Condition Guidance.