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HMRC internal manual

Customs Civil Penalties Guidance

HMRC roles: role of Customer Compliance Manager

HMRC appoints Customer Compliance Managers (CCMs) to have responsibility for, and an overview of, the taxation affairs of large businesses. CCMs work in the Large Business (LB) and in Mid-Size Business (MSB) . The CCM has an important role to play in the Customs Civil Penalty (CCP) process.

Before an intervention to a LB or Mid-Size trader an officer should check whether there is a CCM and, if there is one, they should tell the CCM that they are starting an intervention. A list of current CCMs can be found at (This content has been withheld because of exemptions in the Freedom of Information Act 2000)

CCP action (issuing a warning letter or a penalty notice) should not be taken without the approval of the CCM, who will have established a relationship with the trader and have a full picture of all their tax affairs.

The Customer Compliance Manager is responsible for

  • discussing with the officer any case where the need for a warning letter or a penalty notice has been identified
  • examining all available material, such as the Customs Penalty Action Checklist (CPAC), to allow them to make an informed decision. This will include information which will help them to decide:

    • whether or not there is a reasonable excuse for a contravention, and
    • if a penalty is to be charged, the degree of mitigation to be applied
  • responding promptly to requests from the officer
  • explaining their decision about whether to take CCP action
  • providing written confirmation via e-mail that they have agreed proposed CCP Action.