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Official guidance
Alcohol Wholesaler Registration Scheme

AWRS100000 · Penalties and sanctions

  • AWRS100100 · Overview
  • AWRS100200 · Criminal sanctions
  • AWRS100300 · Civil sanctions - behavioural penalties
  • AWRS100400 · Trading without approval (TWA) overview
  • AWRS100500 · What is trading without approval?
  • AWRS100600 · When is a penalty chargeable for TWA?
  • AWRS100700 · What does not count as trading without approval?
  • AWRS100800 · Trading without approval - types of penalty
  • AWRS100900 · Trading without approval - deliberate and concealed
  • AWRS101000 · Trading without approval - deliberate but not concealed
  • AWRS101100 · Non deliberate trading without approval
  • AWRS101200 · Trading without approval - onus of proof
  • AWRS101300 · Trading without approval - level of proof
  • AWRS101400 · Buying from an unapproved wholesaler overview
  • AWRS101500 · Buying from an unapproved wholesaler - review and appeal
  • AWRS101600 · Buying from an unapproved wholesaler - what amounts to buying from an unapproved wholesaler?
  • AWRS101700 · Buying from an unapproved wholesaler -when is a penalty chargeable for buying from an unapproved wholesaler?
  • AWRS101800 · Buying from an unapproved wholesaler - what does not count as buying from an unapproved wholesaler?
  • AWRS101901 · Buying from an unapproved wholesaler - types of penalty
  • AWRS101902 · Buying from an unapproved wholesaler - deliberate and concealed
  • AWRS101903 · Buying from an unapproved wholesaler - Non-Deliberate
  • AWRS101904 · Buying from an unapproved wholesaler - Onus of proof
  • AWRS101905 · Buying from an unapproved wholesaler - Level of proof
  • AWRS101906 · Penalties and Sanction: Buying from an unapproved wholesaler - Deliberate but not concealed
  1. Penalties and sanctions: contents
  2. Penalties and sanctions: trading without approval - types of penalty

AWRS100800 | Penalties and sanctions: trading without approval - types of penalty

From HM Revenue & Customs · Alcohol Wholesaler Registration Scheme

There are three types of contravention:

  • deliberate and concealed,

  • deliberate but not concealed, or

  • any other case (referred to in this guidance as non-deliberate).

Penalties for trading without approval are designed to address the behaviour that caused the contravention. The more serious the behaviour, the higher the possible penalty will be.

Within the deliberate category, the law provides for higher penalties in the most serious cases where the person has not merely failed to apply for approval, but has also taken steps to conceal the contravention.

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