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HMRC internal manual

Customs Civil Penalties Guidance

CITEX officers operational process: penalty notice: authorisation of penalties: who an authorising officer may be and what action they should take


The Authorising officer is the Compliance manager.

The authorising officer will authorise the issue of the penalty by completing the bottom of the CITEX Penalty Action Checklist (CPAC).

Before authorising a penalty the authorising officer should

  • Check that they have received all of the relevant paperwork

    • Decision-making template
    • CPRAF
    • Completed Penalty Notice
    • All supporting documents
  • Check that the Penalty is accurate in all respects

    • Have the correct trader particulars been included
    • Has the correct legislation been applied
    • Do you agree that the information recorded on the decision making sheet confirms that penalty action is the best course of action to improve compliance
    • Have you checked that when deciding the level of penalty, the officer has taken account of the circumstances surrounding the contravention
    • Have they established whether there was either a reasonable excuse or mitigating factors that they should have considered
    • Have they identified if the trader has taken or is in the process of taking remedial action to improve compliance
    • Have they incorporated RTBH into their decision to issue penalty

All of these factors must be considered to ensure we have a consistent approach to charging penalties. Remember the penalty must be both reasonable and proportionate to both the volume and circumstances surrounding the contraventions.