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HMRC internal manual

Excise Due Diligence Condition guidance

The due diligence condition: establishing reasonable and proportionate

Businesses should have reasonable due diligence procedures and checks in place to consider alcohol sector risks before agreeing to trade. When you are considering whether or not these are sufficient, you should interpret ‘reasonable’ objectively. In other words, the procedures and checks are reasonable if they could be perceived by a neutral observer as reasonable.

A proportionately higher level of due diligence testing is required when the revenue risk is higher. For example, where the deal seems too good to be true or supply routes seem contrived or overly long.