If your due diligence still involves the collection of paper and no further checks or questioning of your customers and suppliers, you are at significant risk of losing HMRC license approvals such as WOWGR and AWRS.
Our team of Due Diligence specialists are on hand to help you. We can review the quality of your due diligence checks for your business ahead of any HMRC compliance visit.
Only collecting paperwork e.g. Certificates of incorporation, Directors Passports and Utility bills is not sufficient. Swapping paper files or not questioning documentation, is insufficient. Documentation must be verified.
Is My Current Due Diligence Good Enough?
If you want to hold and retain an AWRS, WOWGR or Alcohol linked licence, FITTED would apply and there are clear guidelines for MLR due diligence. Modern Slavery also requires appropriate checks to be carried out.
At a high level companies must be prepared to have:
- Evidenced checks undertaken on proposed trading partners
- Visits to premises
- Checklists of documentation received and verified
- Records of questions asked
- Risk assessments made and filed
- Continuous monitoring undertaken whilst trading takes place.
Failure to comply with due diligence requirements and to have written evidence of your checks will likely result in HMRC deeming the business non-compliant. This constitutes reasonable cause to deny or revoke an approval. Consistent lack of checks can result in a finding that individuals are not ‘fit and proper’.
Due diligence applies to all businesses, regardless of their size. There is no defined list of checks that must be carried out. Any any checks must reflect the risks posed by the trading relationship.
Our team can assist you if you have concerns about the quality of your due diligence checks for your current and future business opportunities.
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