AWRS Due Diligence Policy
STATEMENT OF POLICY
Cargo Vista Ltd (Trading As Ashby Wines) is committed to trading in full compliance with all relevant national, EU 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 – Claire Swanepoel, Director.
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
Cargo Vista Ltd (Trading As Ashby Wines) 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.
CARGO VISTA HOLDINGS LTD (T/A ASHBY WINES)
Cargo Vista Ltd (Trading As Ashby Wines) are committed to tackling alcohol fraud on a national level. We work to eliminate risk and aim to ensure Ashby Wines comply with the Excise Due Diligence and AWRC 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: Cargo Vista Ltd (Trading As Ashby Wines)
Trading Address: 16 Smisby Road, Ashby-de-la-Zouch, LE65 2JL
Trading Activity: Wholesaler of Wine, Beer & Spirits & direct delivery to customers through online website
Company number: 11179920
Date of Incorporation: 31st January 2018
VAT Number: 322 6293 18
HMRC Deferment Number: NA
AWRS application number: XSAW 000 0011 6090
WOWGR Excise ID: NA
EORI : GB3226293180000
Phone: 01530 433 274
Email: [email protected]
Website: www.ashbywines.com
With this information, checks can be carried out on the identity and financial health of the company through Companies House in the UK.
Company Structure
Ashby Wines is a trading arm of Cargo Vista Holdings Limited, a limited company and is registered and incorporated through Companies House in the UK. The details of our current board of directors, our registered address and annual accounts are verifiable through their online service.
Ashby Wines Supply Chain
Ashby Wines only source products from reputable businesses. Duty has been paid on all stock, prior to its delivery at Ashby Wines warehousing.
Evidence of Duty Payment
Ashby Wines 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 Ashby Wines, our employees and the Exchequer.
Blank invoices
Blank letterheads
Copies of companies Directors passports
Copies of Directors private address details
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 Ashby Wines we will require you to complete our AWRS form. This will be emailed to you for you to complete.
CARGO VISTA HOLDINGS LTD (T/A ASHBY WINES) – CUSTOMER DUE DILIGENCE POLICY
For a retailer (Off License) or online account through ashbywines.com to open an account:
In order for a business to register for trade, Ashby Wines will require the following documents:
- Copy of Incorporation Certificate
- 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 Ashby Wines 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 (Ashby Wines preferred method is bank transfers and Cards for online sale). Ashby Wines does 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.
CARGO VISTA HOLDINGS LTD (T/A ASHBY WINES) – SUPPLIER DUE DILIGENCE POLICY
As a part of the Alcohol Wholesaler Registration Scheme (AWRS), Ashby Wines is required to conduct due diligence checks on partners involved in the supply chain for alcoholic drinks.
Ashby Wines 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)
- WOWGR 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 accounts officer 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.
Ashby Wines 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 Ashby Wines 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 Ashby Wines to undertake a risk assessment before any account is open. Ashby Wines will only trade with a customer or supplier if they have passed the necessary risk assessment checks. Ashby Wines will only work with suppliers in the alcohol industry who accept payment by cheque or bank transfer. Cash payments are not permitted.
Designated Accounts officer or another authorised member of the team will review the submitted information on a case-by-case basis and a Director 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 by a Director.
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 the designated Accounts officer. All training of the DDCOC must be authorised by Accounts officer or Directors 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.
