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HMRC internal manual

Excise Civil Penalties Manual

Types of penalties: Who can be issued with a penalty

A civil penalty can be issued to any person who is in breach of any excise law that is subject to a Civil Penalty.

This applies to both authorised traders (excise warehousekeepers, brewers etc) and unauthorised person (unregistered casinos, bootleggers etc).

In the case of an authorised trader the penalty should normally be issued to the legal entity but it can be issued to an employee if you can show that the employee was responsible for the default and was acting on their own behalf.