awrs due diligence policy

AWRS URN: XEAW00000118707

1.Policy Statement

Orientalmart UK Ltd are committed to ensuring that our client and customer interactions and business relationships are transparent, legal, suitable, relevant and safe (for the customer and the Company). Having effective due diligence controls and processes in place is essential to the functioning of our business and enables us to provide a compliant service and to ensure that we can minimise the risks of money laundering or terrorist financing within our organisation.

By carrying out due diligence checks and assessments on all employees, customers and business relationships, we aim to protect ourselves and our customers from the risks associated with financial crime, as well as ensuring the suitability and effectiveness of any products/services that we provide.

Our approach to due diligence is multi-tiered and in addition to our due diligence measures, we also assess organisational change and the implementation of any new system/process to ensure that we can mitigate risks and protect the interests of our customers.

2.Purpose

The Purpose of this due diligence policy is to ensure that Orientalmart UK Ltd fully complies with the Alcohol Wholesaler Registration Scheme (AWRS) and HMRC Notice 2002.

We aim to prevent participation in the supply of illicit alcohol, alcohol diverted from the duty system, or trading with high risk suppliers or customers.

3.Roles and Responsibilities

Appointed Company directors and Compliance officer: Enforce the policy, oversee due diligence checks, and maintain records of due diligence actions.

Employees: Understand and adhere to the policy, report concerns promptly, and support due diligence activities as needed. 

4.Due Diligence Requirements

We will carry out due diligence when:

• Opening a new supplier or customer account
• Reviewing existing relationships (at least annually or sooner if risk changes)
• Any red flags appear (e.g., unusually low prices, refusal to share documents)

All documents will be stored securely for at least 6 years.

5.Supplier Due Diligence Procedures

For every alcohol supplier, we will obtain and check:

5.1 Mandatory Documents

• Obatain and Validate AWRS Unique Reference Number (URN) via HMRC’s online look-up service for suppliers if this has been issued in the UK. 
• VAT registration number (verify on VIES)
• Company incorporation documents
• Director/PSC details from Companies House
• Business utility bill or proof of premises
• Bank details (company account only)

5.2 Risk Assessment

We will assess:

• Trading history and reputation
• Price compared to market norms
• Delivery method and warehouse location
• Whether the supplier has any duty-suspension or EMCS movements

5.3 Additional Checks for Higher-Risk Suppliers

• Site visit or video walk-through
• Trade references
• Questionnaires covering supply chain and duty status
• Checking for links to tax losses or phoenixism

5.4 Ongoing Monitoring

• Rechecking AWRS URN annually
• Reviewing any changes at Companies House
• Monitoring for suspicious patterns such as:
  
  Prices below duty + VAT Pressure to pay in cash Requests to divert stock to unknown locations

6.Customer Due Diligence Procedures

For every alcohol-buying customer, we will obtain:

6.1 Mandatory Documents

• AWRS URN (for wholesalers)
• Premises licence or personal licence (retailers)
• Proof of business address
• VAT registration (if applicable)
• Bank details (must match business name)

6.2 Risk Assessment

We will evaluate:

• The nature of the customer’s business
• Whether the volumes ordered match their trading model
• Unusual payment requests
• Delivery patterns or stock movement concerns

6.3 Ongoing Monitoring

• Annual refresh of documents
• Checking for red flags such as:
  
  Orders inconsistent with business size Payments from unrelated third parties Customers requesting delivery to non-business premises

7.High-Risk Indicators (Red Flags)

We will not trade if any of the following occur:

• Prices too low to be legitimate
• Supplier/customer unwilling to provide documents
• Sudden large cash payment requests
• Unknown third-party collection of goods
• Inconsistent or suspicious paperwork
• High-risk transport or warehouse routes

8.Record Keeping

Orientalmart UK Ltd is committed to maintaining accurate and up-to-date records of all due diligence activities

• All due diligence documents
• Purchase and sales invoices
• Delivery notes and PODs
• Transport documentation (CMRs, courier tracking)
• Duty-suspension paperwork (EMCS, ARC) where applicable

Records are stored securely and are available for HMRC inspection.

9.Staff Training

All staff involved in alcohol trading will: 

• Receive training on AWRS and Notice 2002 requirements
• Be aware of red flags and escalation procedures
• Report concerns to the responsible person immediately

10.Escalation & Refusal to Trade

If red flags are identified: 

1. Trade is placed on hold
2. Risk is reviewed by the responsible person
3. Documentation or clarification is requested
4. Trade may be refused or the relationship terminated
5.  A log will be kept of all declined business due to risk.

11. Policy Review

This policy will be reviewed annually or in response to regulatory updates to ensure ongoing compliance with AWRS and HMRC requirements.