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HMRC internal manual

Holding and Movements Assurance Guidance

Registration and approval: Continuing to monitor approved/authorised traders

After a trader has gained the necessary excise warehouse premises approval, warehousekeeper, registered owner, duty representative, registered consignor, registered consignee, temporary registered consignee, registered commercial importer or tax representative approval/authorisation, the business must be closely monitored. Officers should regularly test the credibility and suitability of the approved/authorised person to ensure that they continue to fulfil the requirements necessary to operate the business and remain approved/authorised.

We currently operate a risk based assurance programme that selects traders and tests their compliance. A number of sanctions are at our disposal to encourage compliance and reduce risk. These include varying the terms of the approval/authorisation by adding specific conditions or restrictions and, where significant risk is identified, revoking (cancelling) the approval. Details of other sanctions which can be considered by officers can be found at HMAG32100 

RIS Ops will notify assurance officers when a post-approval visit is required. Newly approved warehousekeepers should be closely monitored and receive a post-approval visit within the first year of trading. As part of the post-approval visit the guarantee should also be reviewed (seeHMFSA guidance). Warehousekeeper authorisations can be revoked immediately as there is no requirement for a probationary period, however, see HMAG31600 which allows for a revocation period of one month on the warehousekeeper authorisation with the option for officers to impose conditions and restrictions on the premises approval if deemed appropriate.

In the case of a newly approved warehouse, the initial premises approval is only valid for 12 months. At 6 months the officer should review the approval and if serious non-compliance is identified, the approval should be revoked and not renewed.

If there are doubts over non-compliance, the officer should re-approve for a further period and either give the trader written notice of the areas of non-compliance or consider the imposition of additional conditions.

Where the warehousekeeper is compliant, the approval is normally extended indefinitely.

RIS Ops should be provided with feedback on all action taken. This is normally done by the officer sending them a copy of the Caseflow narrative visit report.