AWRS | Mamba Logistics

MAMBA LOGISTICS AWRS DUE DILIGENCE POLICY

STATEMENT OF POLICY

Mamba Logistics Limited is committed to complying with all relevant national and international laws, and the regulatory bodies that enforce them. Under the Alcohol Wholesaler Registration Scheme (AWRS), Mamba Logistics Limited are required to conduct due diligence checks on both customers and suppliers involved in our supply chain for alcoholic drinks.

Due diligence is important for our business to 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.

In accordance with the above 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 on customers or other trading partners where we think there is a possibility that this could involve a fraudulent transaction.

We have close regard for “know your customer” requirements as set out in 2017 Money Laundering Regulations as amended from time to time.

If we identify fraud or suspicious activity in respect of our alcohol supply chains, HMRC will be notified in a timely manner through our Lead Contact – Warren Cunningham, Director.

Any customers or suppliers identified as high risk will undergo further questioning before we decide if we will enter into a trading relationship. Due diligence will be evaluated every 3 months for high risk customers/suppliers, annually for all others, with regular reviews to highlight any changes in activity so the appropriate actions can be taken.

Any customers or suppliers who do not pass our internal checks will be notified that we are unable to open an account and unable to trade. Any business with suspicious behaviour will be reported to HMRC in a timely manner.

Information submitted will be reviewed on a case-by-case basis and a company director will conduct final sign off at their discretion.

All initial checks and further reviews will be electronically recorded and shared with HMRC as appropriate.

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.

RISK ASSESMENT AND CHECKS PROCESSES

Mamba Logistics Limited has adopted processes in order to:

Check the identity of trading partners;
Check the financial health of trading partners;
Check contract terms with suppliers and customers;
Check the existence and provenance of goods that we buy and sell;
Assess the credibility of the commercial deals being entered into.

It is integral to these processes that in each case we will assess how much information we need in order to justify relationships or specific transactions in the context of all relevant regulations. When we receive information, we will, as far as possible, cross-check it with independent sources as appropriate.

REVIEW

This policy will be reviewed by the Directors from time to time, as required.

MAMBA LOGISTICS LIMITED

Mamba Logistics Limited is committed to tackling alcohol fraud on a national level within the UK. We work to eliminate risk and aim to ensure that we comply with all requirements and regulations and insist that all of our customers and suppliers perform due diligence on us in return.

The following information has been prepared to support and confirm Mamba Logistics Limited as ‘fit and proper’ in compliance with HMRC Regulations.

Company Name: Mamba Logistics Limited

Trading Name: Mamba Logistics Limited Company Registration Number: 13377958 Trading Address: 113-115 Oyster Ln, West Byfleet KT14 7JZ Telephone Number: 07853194426 Email: warren@mambalogistics.co.uk Trading Activity: Wholesaler of Imported South African food and beverages via direct sales and online. Web Address: www.mambalogistics.co.uk Type of organisation: Private Limited Company EORI : GB082112252000 VAT Number : 381870768 AWRS: XNAW00000118279

With this information, checks can be carried out on the identity and financial health of the company through Companies House in the UK. Should you require further information please contact us and we will attempt to accommodate, whilst considering the sensitivity of the information required, and the risks of providing such information in the context of fraudulent activity.

DOCUMENTS THAT WE ARE UNABLE TO SUPPLY

The following is a list of documents which we cannot provide to customers due to the risk of fraud.

Blank invoices
Blank letterheads
Copies of companies Directors passports
Copies of Directors private address details
Bank statements
Utility bills

DUTY PAID

Mamba Logistics Limited supplies all our stock duty paid. Please note 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 will include our Alcohol Wholesaler Registration Scheme URN.

UK CUSTOMERS & SUPPLIERS

For companies operating within the UK to become a customer/supplier for alcoholic goods to Mamba Logistics Limited, we will perform due diligence that will require your assistance in the provision of information and documentation as appropriate. The below serves as a general guide for information we will require.

SELLING ALCOHOL – FOR RETAILERS TO OPEN AN ACCOUNT

In order for a business to register for trade, the following documents are required by Mamba Logistics Limited:

Copy of Incorporation Certificate
Copy of VAT certificate (if registered)
Company Bank Details
Owner Photo ID (Passport or Driving Licence)
Copy of Business Utility Bill (within previous 3 months)
Fill in Due Diligence Questionnaire

We will perform our checks/risk assessment as soon as we receive all of the above. Payment methods accepted are Card or Bank Transfer only. Mamba Logistics Limited does not accept cheques or cash. All initial checks and further reviews will be electronically recorded. All high risk suppliers will be reviewed every three months; all other suppliers will be reviewed on an annual basis. All customers who do not pass our 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.

BUYING ALCOHOL – FOR UK BASED SUPPLIERS

In order for Mamba Logistics Limited to engage in trade with UK based suppliers, we will require the following information.

Company Introduction stating nature of business and products available.
Payment terms, including returns policy, insurance provisions, and details specific to goods sold.
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)

We will perform our checks/risk assessment as soon as we receive all of the above. 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.

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