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HMRC internal manual

Excise Due Diligence Condition guidance

Risks: transport

Businesses should be aware of transport related risk and test for these where relevant. This is because the movement of goods is at the heart of all diversion fraud. The business should consider for each trading arrangement:

  • who arranges the transport
  • who has control over the transport (and may be implicated in fraudulent supply chains)
  • transport logistics
  • how transport arrangements are made in practice

We would expect a business to react positively to the following transport risks (please note this list is not definitive):

  • the goods are received from an unusual source or supply route, for example, UK produced goods sourced from another country, which directly compete with UK supplies
  • the potential logistical costs make the unit price of the goods unrealistic.