STATEMENT OF POLICY FOR ALCOHOL WHOLESALER REGISTRAITION SCHEME – DUE DILIGENCE
HMRC Alcohol Wholesaler Check https://www.gov.uk/check-alcohol-wholesaler-registration
Reynolds Cocktails Ltd is committed to trading in full compliance with all relevant national and international laws. We will:
Objectively assess the risks of alcohol duty fraud within the supply chains in which we operate.
Put in place reasonable and proportionate checks, in our day-to-day trading, to identify transactions that may lead to fraud
or involve goods on which duty may have been evaded.
Have procedures in place to take timely and effective mitigating action where a risk of fraud is identified; and
Document the checks we intend to carry out and have governance in place to ensure that these are, and continue to be, carried out as intended or customer or other trading partner where we think there is a possibility that this could involve a fraudulent transaction.
We have close regard to “know your customer” requirements as set out in 2017 Money Laundering Regulations as amended from time to time.
If we suspect fraud, HMRC will be notified through our Lead Contact – Christopher Reynolds.
All customers who do not pass the internal checks will be notified that their account will not be opened and customers with suspicious behaviour will be reported to HMRC in a timely manner.
We will not inform you when or in what manner or to whom we report suspicious behaviour.
CONSEQUENCE OF NON-COMPLIANCE
Failure to demonstrate due diligence may lead HMRC to conclude that a business is a risk to the revenue and not “fit and proper” for the purpose of excise legislation. This may lead to restrictions or conditions being imposed and, ultimately, to the withdrawal of authorizations, financial penalties, prosecutions and the seizure of stock.
PROCESSES
Christopher Reynolds (Trading as Reynolds Cocktails Ltd) has adopted and documented processes that will:
Check the identity of trading partners.
Check the financial health of trading partners.
Check the contract terms.
Check the existence and provenance of goods that we buy and sell.
Assess the credibility of the deal being contemplated
It is integral to those processes that in each case we will assess (having regard to said 2017 Regulations) how much information we need in order to justify the relationship or specific transaction. When we receive information, we will, as far as possible, cross-check it with independent sources.
REVIEW
This policy will be reviewed by the Business owners as required.
Christopher Reynolds (Trading As Limited Company - Reynolds Cocktails Ltd) is committed to tackling alcohol fraud on a national level. We work to eliminate risk and aim to ensure Reynolds Cocktails Ltd comply with the Excise Due Diligence and AWRS and insist that our customers and suppliers alike perform these check on us in return.
HMRC deems checks to be risk based, however we appreciate that for many of our customers it is impossible to risk assess all their suppliers with this in mind the following information is provided to help you meet your due diligence obligations.
Trading Name: Reynolds Cocktails Ltd
Trading Address: UNIT 1, Meilke Clinterty Farm, Kinellar, Aberdeen, AB21 0TZ
Trading Activity: Mobile Cocktail Bar, plus Wholesaler of Ready to Drink Cocktails
Legal Status – Limited
Date of Start: 1st June 2023
VAT Number: 386237175
AWRS application number: PENDING
WOWGR Excise ID: NA
Phone: 07588555493
Email: info@reynoldscocktail.com
Website: www.reynoldscocktails.com
With this information, checks can be carried out on the identity of the company. Financial records are available on request in order to support any checks under taken by clients and suppliers.
Company Structure
Reynolds Cocktails, a limited company and is registered for VAT, Corporation Tax and Self Assessments. Company Number SC769587r
reviews from previous clients can be provided by online searches via Google or Social Media, as well as contacting us and speaking to us directly.
Reynolds Cocktails Supply Chain is to only source products from reputable businesses. Duty has been paid on all stock, prior to its delivery at the unit.
Evidence of Duty Payment
Reynolds Cocktails will supply all our stock duty paid. We do not provide evidence of duty payment to customers. We will only supply this information and such evidence directly to the HMRC upon their request. Relevant invoices include our Alcohol Wholesaler Registration Scheme number.
Documents that We are Unable to Supply
The following is a list of documents which we cannot provide to customers as in the wrong hands they present a considerable potential for fraud to be conducted against Reynolds Cocktails, our employees and the Exchequer.
Blank invoices
Blank letterheads
Copies of companies Directors passports
Bank statements
Utility bills
We trust that this information provides all you require to satisfy your Excise Due Diligence requirements. Should you have any questions with regards to this matter then please do not hesitate to contact us.
OUR SUPPLIER AWRS FORM
For your company to become a supplier of alcoholic goods to Reynolds Cocktails we will require you to complete our AWRS form. This will be emailed to you for you to complete.
Reynolds Cocktails – CUSTOMER DUE DILIGENCE POLICY
For a retailer (Off-Sales) or online account through www.reynoldscorporateandcocktail.com to open an account:
For a business to register for trade, Reynolds Cocktails will require the following documents:
Copy of Incorporation Certificate (if appropriate)
Copy of VAT Certificate
Company Bank Details
Owner Photo ID details such as Passport or Driving License
Copy of Business Utility Bill (Less than 3 months old)
Once Reynolds Cocktails has collated this information, the necessary checks will be conducted before opening the account. Any customers identified as high risk will undergo further questioning. High risk customers that are accepted will be evaluated every three months; all other customers will be reviewed on an annual basis.
Payment methods are Card or Bank Transfer only (Reynolds Cocktails Ltd preferred method is bank transfers and Cards for online sale). We do not accept cheques.
All customers who do not pass the internal check will be notified that their account will not be opened and customers with suspicious behaviour will be reported to HMRC in a timely manner.
Christopher Reynolds (Trading as - Reynolds Cocktails Ltd) – SUPPLIER DUE DILIGENCE POLICY
As a part of the Alcohol Wholesaler Registration Scheme (AWRS), Reynolds Cocktails Ltd is required to conduct due diligence checks on partners involved in the supply chain for alcoholic drinks.
Reynolds Cocktails Ltd will require the following documents from a wholesaler to open an account:
Company Introduction stating nature of business and products available
Payment terms, including returns policy, insurance provisions, details on what provisions are the goods sold, i.e. ex-cellars, FOB, delivered, etc
Company Bank Details
Company details including:
Company Registration Number
VAT Registration Number
HMRC Deferment Number (if applicable)
Excise Registration Number
Warehouse Address
AWRS Number (URN)
If you are a UK duty paid supplier, please provide us with copies of form W-5 (or similar document) showing evidence of duty payment.
Once the supplier has sent the above information, the appointed Christopher Reynolds or another trained member of the team will review it. The overall risk of the supplier will be established. If the business is identified as a high risk supplier, further questions will be asked and site visits will be conducted as appropriate. Any suspicious retail pricing at uneconomic levels or improper trading patterns will be reported to HMRC in a timely manner.
All high risk suppliers will be reviewed every three months; all other suppliers will be reviewed on an annual basis.
Reynolds Cocktails Ltd Due Diligence Code of Conduct (DDCOC) sets out the basic rules we will follow and the values that will guide our decisions. It also points us to a more detailed processes and procedures relating to the purchase and supply of alcoholic products.
The DDCOC is built on the premise of ‘knowing your customer or supplier and the commercial transactions that will be involved. Supply chains are only as strong as the weakest link and the purpose of Reynolds Cocktails Ltd DDCOC is to prevent entering into commercial transactions with any illicit customer or supplier. The policy will aid in ensuring all customers and suppliers are regularly reviewed so any changes of activities are identified, and the appropriate action taken.
Specific guidelines have been developed for customers and suppliers. All customers and suppliers must provide the required list of documents and completed questions for Reynolds Cocktails Ltd to undertake a risk assessment before any account is open. Reynolds Cocktails Ltd will only trade with a customer or supplier if they have passed the necessary risk assessment checks. Reynolds Cocktails Ltd will only work with suppliers in the alcohol industry who accept payment by bank transfer or online card payment. Cash payments are not permitted.
Christopher Reynolds or another authorised member of the team will review the submitted information on a case-by-case basis and will conduct the final sign off. Any customer or supplier who fails to pass the risk assessment will immediately have all transactions ceased pending review. If the review is unsatisfactory, the account will be closed indefinitely.
Regular reviews of customer and supplier information will be conducted by an Accounts officer or another authorised member of the team and the final sign off will be conducted.
All initial checks and further reviews will be documented in the customer or supplier file and maintained on an ongoing basis. Reminders for checks should be logged onto the accounting software and Outlook calendars.
The DDCOC will be implemented and maintained by Christopher Reynolds. All training of the DDCOC must be authorised by Christopher Reynolds and any changes in staff will undergo full training on the DDCOC. Part of the DDCOC is to ensure day-to-day checks are in place to identify transactions that may lead to fraud or involve goods on which duty may have been evaded. Checks in purchase order processing and customer orders are two areas where daily checks are performed.