Regal Whisky Due Diligence Policy
Regal Whisky Limited
100 Leeside Crescent
London
NW11 0LA
Company Number: 11066641
VAT number: 307089993
As part of the Alcohol Wholesaler Registration Scheme (AWRS) Regal Whisky Limited are required to conduct due diligence checks on both customers and suppliers involved in the supply chain for alcoholic drinks. Due diligence is important for Regal Whisky Limited's business and ensures that we minimise exposure to commercial risk, reduce the risk of being exposed to fraudulent transaction chains and reduce the risk of being exposed to significant financial losses.
Regal Whisky Limited is committed to making due diligence an obligation for all businesses we are involved with in alcohol. Due diligence will help drive fraudsters from the market place, increase consumer confidence in the sector, boost legitimate businesses by restoring a level playing field and help maintain confidence and reputation.
Regal Whisky Limited carry out extensive due diligence checks following the guidelines from HMRC and the FITTED checks (see: HTTPS://WWW.GOV.UK/HMRC-INTERNAL-MANUALS/EXCISE-DUE-DILIGENCE-CONDITION/EDDC02030) as a structure to establish potential risk within our supply chains. Through these due diligence checks Regal Whisky Limited ensure we “know our customer and supplier”. Any customers or suppliers identified by us as high risk will undergo further questioning before Regal Whisky Limited will make a decision as to whether we will begin to trade. Due diligence checks will be evaluated every six months for high risk customers or suppliers, and annually for all others. Regal Whisky Limited will carry-out regular reviews to highlight any changes in activity amongst our customers or suppliers so that timely and appropriate actions can be taken.
As part of our Due Diligence approach all customers and suppliers will be required to provide the list of documents specified by Regal Whisky Limited and satisfactorily answer questions / complete a questionnaire to enable Regal Whisky Limited to undertake an appropriately detailed risk assessment before any account is opened. Regal Whisky Limited will only trade with a customer or supplier that has received confirmation from us that they have passed the assessment checks.
Any customers or suppliers who fail to pass our Due Diligence checks will be notified in writing and will not be in a position to open an account or trade with us. Any business that we identify exhibiting suspicious behaviour will be reported to HMRC in a timely manner.
Information submitted will be reviewed on a case-by-case basis and the company director will conduct final sign off.
All initial Due Diligence checks and further or subsequent reviews will be documented electronically in an appropriate customer or supplier file. A calendar for on-going management of Due Diligence checks will be maintained, with reminders for carrying out periodic checks and assessments logged in Regal Whisky's CRM system and utilising Google calendar reminders.
Day-to-day checks will be carried out to identify any potential transactions that may lead to fraud or involve goods on which duty may have been evaded. These checks are made on both supplier purchase ordering and customer sales orders.
Purchase ordering
All orders are raised through official purchase orders for approved suppliers. The orders are emailed across to our supplier directly with the full details of the product and price. Once the goods are received into our warehouse the goods are booked into our stock management system which will highlight any errors for example product type or quantity. If any delivery is not received within the expected time, Regal Whisky raise a query with the supplier, courier or haulier.
Customer ordering
For any new sales, we will first check that the customer’s due diligence file is up to date at the same time we review the due date. Customer orders are received in writing by email. Orders are then assessed alongside the due diligence information provided by the customer, on a case-by-case basis.
Documentation required in order to consider opening a customer account with Regal Whisky.
The documents required include, but may not be limited to:
1. Completed Regal Whisky Limited Due Diligence questionnaire (completed online)
2. Company Incorporation Certificate
3. VAT Certificate
4. Company Owner's / Director’s / Photo ID (Passport)
5. Copy of a business utility bill (less than 3 months old)
6. Company Bank Details
7. AWRS number
8. Signed letter of introduction on headed letter paper
9. Company Bank Details
10. Copy of Lease agreement or proof of Freehold of the business premises
Once the relevant information has been provided, Regal Whisky Limited will review the information provided and carry out our risk assessment.
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 method is by Credit or Debit card only. We do not accept third party card payments.
Documentation required in order to consider opening a Supplier Account with Regal Whisky
As a part of the Alcohol Wholesaler Registration Scheme (AWRS), Regal Whisky Limited is required to conduct due diligence checks on partners involved in the supply chain for alcoholic drinks. Regal Whisky Limited will require the following documents for a wholesaler to open an account to start trading with us. The documents required include, but may not be limited to:
1. Completed Regal Whisky Limited Due Diligence questionnaire (completed online)
2. Company Incorporation Certificate
3. VAT Certificate
4. A copy of company’s most recently filed Annual Accounts
5. A copy of Money Laundering Certificate (if applicable)
6. Company Owner's / Director’s / Photo ID (Passport)
7. Company Bank Details
8. AWRS number
9. Copy of a business utility bill (less than 3 months old)
10. Signed letter of introduction, with Director’s Signature, on headed letter paper
11. Proof of the Due Diligence the company carries out
12. Copy of Company’s terms and conditions for trading
13. UK Duty Paid Suppliers are required to provide Regal Whisky Limited with copies of form W5 (or similar document) providing evidence of duty payment
Once the relevant information has been provided, Regal Whisky Limited will review this and carry out our risk assessment. The process will establish the overall risk presented by the supplier/business. If the business is identified as a high-risk supplier, further questions will be asked, and or site visits will be conducted as deemed appropriate. Any suspicious retail pricing at what Regal Whisky consider to be uneconomic levels or improper trading patterns will be reported to HMRC in a timely manner. All high-risk suppliers will be subject to Due Diligence reviews every three months; irrespective of this all suppliers will be regularly reviewed on an annual basis.
Last updated: June 2022