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HMRC internal manual

Customs Civil Penalties Guidance

HM Revenue & Customs
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Warning letter: Record-keeping and reporting


If a compliance officer decides that a Customs Penalty Warning Letter (CPWL) is appropriate, they must keep a complete and accurate record of their decision-making process on the Customs Penalty Action Checklist (CPAC). This will help when the authorising officer is considering whether to agree the issue of the CPWL but it is also possible that the decision to issue a CPWL could be subject to the formal appeal and review procedure, and this record may be needed at tribunal.

In practice this means that you must keep a copy of your agreed CPAC. This record must contain enough detail to substantiate the decision.

Once they have issued the CPWL, the compliance officer should ask their manager to sign in the box at the bottom of the CPAC to say that the action is completed.

Compliance officers should store copies of the CPWL and CPAC on Caseflow.

Where appropriate, a paper copy should be put into the trader’s folder.


The Compliance officer should record the issue of the CPWL on Caseflow once they have issued it.