Posted: 28/10/15 by Altion Law Ltd
As many of our clients are aware, the date for registration with the AWRS has been postponed to 1st January 2016.
Whilst this has given companies the busy winter trading period to ensure their compliance processes are robust enough to meet AWRS requirements, it has not removed the need to ensure your company is complying with FITTED due diligence requirements which have been in effect for WOWGR holders since November 2014.
From 1st Jan 2016 alcohol wholesalers, brokers, auction houses and anyone who retails alcohol in the ‘course of their business’ must register with HMRC.
Failure to do so could lead to financial and civil penalties.
Ahead of registration, companies should ensure they have implemented and updated the following to ensure they adequately reflect the AWRS requirements.
• Policies and processes
• Risk assessments for customers and suppliers
• Enhanced due diligence to FITTED levels
• Undertaking of continuous monitoring activity
• Training of staff AWRS has implications such as essentially removing the 72hr duty payment window for non AWRS companies and day passes for Cash and Carry’s become a much ‘riskier’ area without a clear due diligence process.
The AWRS is going to impact the wholesale drinks industry and change how a number of companies operate.
It is wise to ensure you are aware of the risks to yourself personally and to your company.
Altion Law is already supporting clients with preparation for the AWRS process and can assist companies of any size managing their compliance function.
We offer services ranging from due diligence checks on suppliers and customers to full assistance with running your compliance or due diligence function.