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HMRC internal manual

Customs Civil Penalties Guidance

CITEX officers operational process: penalty notice: considering mitigation: advising the trader


When you have decided on the amount of the penalty taking any mitigation into account and where appropriate it has been agreed by an Authorising officer, you will issue the penalty.

This applies whether you have considered the factors

  • at the time you prepared the penalty notice or
  • if new information is provided by the trader after the penalty has been issued.

If the trader or their representative presents additional facts in order to increase the mitigation allowed, you should consider whether the further information is sufficient to justify a further ‘step’ (or steps) of 10% of mitigation. If you feel further mitigation is not appropriate and the authorising officer agrees, you should notify the trader of your decision and explain their review and appeal rights.