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HMRC internal manual

Customs Civil Penalties Guidance

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


The Authorising officer for Non-Citex officers is the CPO.

The authorising officer will authorise the issue of the Civil Penalty Warning Letter (CPWL) by completing the bottom section of the CITEX Penalty Action Checklist (CPAC).

Before authorising a warning letter, the authorising officer should

  • Check that they have received all of the relevant paperwork

    • Completed draft CPWL
    • CPAC
    • All 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 decision making sheet confirm that a warning letter is the best course of action to improve compliance
    • Has the compliance officer established whether there was a reasonable excuse 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 a warning letter if the contravention is under reason code 230

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