beta This part of GOV.UK is being rebuilt – find out what beta means

HMRC internal manual

Customs Civil Penalties Guidance

CITEX officer operational process: warning letter: who an authorising officer might be and what actions they should take


The authorising officer for a CITEX officer is their manager.

A Civil Penalty Warning Letter (CPWL) is authorised by completing the lower section of the CITEX Penalty Action Checklist (CPAC).

Before authorising a warning letter, the authorising officer should:

  • if the trader has a CRM ensure they have approved the CPWL action
    • check that they have received all of the relevant paperwork
    • completed draft CPWL
    • CPAC
    • any other supporting documents
  • check that the warning letter is accurate in all respects
    • have the correct trader particulars been included
    • has the correct legislation been applied
    • does the information recorded on the CPA confirm that a warning letter is the best course of action to improve compliance
    • has the compliance officer established whether a reasonable excuse should have been considered
    • have they identified if the trader has taken or is in the process of taking remedial action to improve compliance
    • have they incorporated Right To Be Heard (RTBH) into their decision to issue a warning letter if the contravention is under reason code 230 Failure to Produce

All of these factors must be considered to ensure we have a consistent approach to issuing warning letters.