The due diligence condition: condition in Notices 196, 203A, 204A, 204B and 226
The condition in each notice states:
“What am I expected to do?
From 1/11/2014, it becomes a condition of your approval as a registered [brewery/consignee/temporary consignee/commercial importer/tax representative/excise warehousekeeper] that you must:
- objectively assess the risks of alcohol duty fraud within the supply chains in which you operate
- put in place reasonable and proportionate checks, in you day to day trading to identify transactions that may lead to fraud or involve goods on which duty may have been evaded
- have procedures in place to take timely and effective mitigating action where a risk of fraud is identified, and
- document the checks you intend to carry out and have appropriate management governance in place to ensure that these are, and continue to be, carried out as intended”
Each notice provides further guidance to the business to help them assess the risks in their supply chain(s) and detail of checks the business should consider.