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HMRC internal manual

Customs Civil Penalties Guidance

CITEX officers operational guidance: penalty notice: action to take once you have arrived at a decision


Once you have considered whether a penalty is appropriate, following the guidance at CCPG27210 - CCPG27290, and arrived at a decision, your next action is set out in the table below. It shows the situations that are possible when the compliance officer has completed the CPAC, got their manager’s recommendation and considered a penalty.

Compliance Officer (CO) decisions

Penalty not appropriate

This may be because:

  • there is a reasonable excuse or
  • education is more appropriate or
  • they are recommending changes/revocation of authorisation, or
  • letter of written instruction is more appropriate.

The CO seeks authorisation of their decision from an Authorising Officer (AO). If the AO agrees that a penalty is not appropriate they will discuss alternative action with the CO.

If the AO thinks a penalty should be issued the CO will take action below.

Penalty appropriate

CO sends CPAC and any supporting documents to their AO for authorisation, having sought approval from the Customer Compliance Manager (CCM) where appropriate.

If the AO agrees with the issue of the Penalty Notice, the CO will obtain reference number, see CCPG30640 and issue the Penalty Notice to the trader. Copy it to CCP Network and CCM.

If the AO thinks a Penalty Notice is not appropriate, they will discuss further actions with CO.

This information is presented in a different way in the flowchart at CCPG30320