AWRS110100 | Calculating the penalty: trading without approval - before calculating the penalty
From HM Revenue & Customs · Alcohol Wholesaler Registration Scheme
You need to have established:
the underlying behaviour that gave rise to the failure, for example. deliberate and concealed
whether the disclosure was unprompted or prompted, see AWRS110700
the quality of disclosure, see AWRS110600.
For detailed guidance on how to calculate the penalty please see AWRS111200.