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HMRC internal manual

Wine Guidance

Security: revenue risk indicators

New wine producers - all wine producers applying for an excise licence are subjected to a structured process of pre-licensing checks - WINE02140 ‘Revenue risk’ gives further details.

Current licensed wine producers - the wine producer’s compliance record is to be examined to form an overview in respect of risk posed to the revenue. To this end, the following factors (in ascending order of significance) are worthy of consideration as indicators of risk:

  • fraud/offence case history
  • penalties previously imposed
  • incidence of under declarations and/or irregularities
  • late and/or non-payment of returns or assessments
  • incidence of warning letters (for example, breaches of approval conditions)
  • reliability of wine producer’s management controls
  • wine producer’s level of co-operation in revenue matters

If the overview indicates that a wine producer is a revenue risk, you will need to assess the deterrent effect of imposing security (CEMA section 157 refers) in relation to other available measures such as the withdrawal of approval to hold wine in duty suspense or taking future civil/criminal offence action. It is important to consider all such enforcement options and to select the most effective revenue safeguard in the prevailing circumstances.