Due Diligence Statement

PrimeCask Trade Ltd is committed to trading in full compliance with all relevant national, EU and international laws. 

We will:

Objectively assess the risks of alcohol duty fraud within the supply chains in which we operate.

  • Put reasonable and proportionate checks in our daily 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 planned by the customer or another trading partner where there is a possibility that this could involve a fraudulent transaction.

We closely regard the “know your customer” requirements set out in the 2017 Money Laundering Regulations, as amended from time to time. If we suspect fraud, HMRC will be notified through our company. All customers who do not pass the internal checks will be notified that their account will not be opened, and customers with suspicious behaviour will be reported to HMRC promptly. We will not inform you when, in what manner, or to whom we report suspicious behaviour.

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 excise legislation. This may lead to restrictions or conditions being imposed and, ultimately, to the withdrawal of authorisations, financial penalties, prosecutions, and the seizure of stock.

Processes

Prime Cask Trade Ltd has adopted and documented processes that will:

  1. Check the identity of trading partners;

  2. Check the financial health of trading partners;

  3. Check the contract terms;

  4. Check the existence and provenance of goods that we buy and sell;

Assess the credibility of the deal being contemplated, It is integral to those processes that, in each case, we will assess (regarding said 2017 Regulations) how much information we need to justify the relationship or specific transaction. When we receive information, we will, as far as possible, cross-check it with independent sources.

Review

This policy will be reviewed by the Business owners as required.

Prime Cask Trade Ltd 

Prime Cask Trade Ltd is committed to tackling alcohol fraud nationally. We work to eliminate risk and aim to ensure Prime Cask Trade Ltd complies with the Excise Due Diligence and AWRC. We insist that our customers and suppliers perform these checks on us in return.

HMRC deems checks to be risk-based. However, we appreciate that for many of our customers, it is impossible to risk-assess all their suppliers. With this in mind, the following information is provided to help you meet your due diligence obligations.

Trading Name: Prime Cask Trade Ltd

Trading Address: 167-169 Great Portland Street, Fifth Floor, W1W 5PF London, England.

Trading Activity: Wholesaler of Spirits & direct delivery to customers through an online website

Company number:  16023711

Date of Incorporation: 17 October 2024

AWRS application number: TBC

VAT Registration Number: Pending 

WOWGR Number: TBC

Excise Registration Number: TBC

Warehouse Address: TBC

Phone: +44(0)20 3951 1725

Email: admin@primecask.co.uk

Website: www.primecask.co.uk (under construction)

With this information, checks can be carried out on the company's identity and financial health through Companies House in the UK.

Company Structure

Prime Cask Trade Ltd is a limited company registered and incorporated through Companies House in the UK. Our current board of directors, registered address, and annual accounts can be verified through their online service.

Supply Chain

Prime Cask Trade Ltd only sources products from reputable businesses. Duty was paid on all stock before its delivery at Prime Cask Trade Ltd warehousing.

Evidence of Duty Payment

Prime Cask Trade Ltd supplies all our stock duty paid. 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 include our Alcohol Wholesaler Registration Scheme number.

Documents that We are Unable to Supply

The following is a list of documents that we cannot provide to customers. In the wrong hands, they present considerable potential for fraud against Prime Cask Trade Ltd, our employees, and the Exchequer.

  • Blank invoices

  • Blank letterheads

  • Copies of companies' Directors passports

  • Copies of Directors' private address details

  • Bank statements

  • Utility bills

This information provides all you require to satisfy your Excise Due Diligence requirements. If you have any questions about this matter, please do not hesitate to contact us.

Our Suppliers AWRS Form

For your company to become a supplier of alcoholic goods to Prime Cask Trade Ltd, we require you to complete our AWRS form. 

Customer Due Diligence Policy


For a retailer (Off License) or online account through www.primecask.co.uk to open an account:

For a business to register for trade, Prime Cask Trade Ltd will require the following documents:

  • Copy of Incorporation Certificate

  • Copy of VAT Certificate

  • Company Bank Details

  • Owner Photo ID details such as Passport or Driving License

  • Copy of Business Utility Bill (Less than 3 months old)

Once Prime Cask Trade Ltd has collated this information, the necessary checks will be conducted before opening the account. Any customers identified as high-risk will undergo further questioning. High-risk customers who are accepted will be evaluated every three months, and all other customers will be reviewed on an annual basis.

Payment methods are Card or Bank Transfer only (Prime Cask Trade Ltd's preferred method is bank transfers and Cards for online sales). Prime Cask Trade Ltd does not accept cheques.

All customers who do not pass the internal check will be notified that their account will not be opened, and customers with suspicious behaviour will be reported to HMRC promptly.

SUPPLIER DUE DILIGENCE POLICY

As a part of the Alcohol Wholesaler Registration Scheme (AWRS), Prime Cask Trade Ltd must conduct due diligence checks on partners involved in the supply chain for alcoholic drinks.

Prime Cask Trade Ltd will require the following documents from a wholesaler to open an account:

Company Introduction stating the nature of the business and products available

Payment terms, including returns policy, insurance provisions, details on what provisions are the goods sold, i.e. ex-cellars, FOB, delivered, etc

  • Company Bank Details

  • Company details include:

  • 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 copies of form W-5 (or a similar document) showing evidence of duty payment.

Once the supplier has sent the above information, the appointed accounts officer or another trained team member will review it. The supplier's overall risk 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, and all other suppliers will be reviewed annually.

Prime Cask Trade Ltd's Due Diligence Code of Conduct (DDCOC)

Prime Cask Trade Ltd's Due Diligence Code of Conduct (DDCOC) sets out the basic rules we will follow and the values that will guide our decisions. It also points us to more detailed processes and procedures relating to purchasing and supplying alcoholic products.

The DDCOC is built on the premise of 'knowing your customer or supplier and the commercial transactions involved. Supply chains are only as strong as the weakest link, and the purpose of Prime Cask Trade Ltd DDCOC is to prevent entering into commercial transactions with any illicit customer or supplier. The policy will ensure that all customers and suppliers are regularly reviewed to identify any activity changes and the appropriate action is taken.
Specific guidelines have been developed for customers and suppliers. 

All customers and suppliers must provide the required list of documents and completed questions for Prime Cask Trade Ltd to undertake a risk assessment before any account is opened. Prime Cask Trade Ltd will only trade with a customer or supplier who has passed the necessary risk assessment checks. Prime Cask Trade Ltd will only work with suppliers in the alcohol industry who accept payment by cheque or bank transfer. Cash payments are not permitted.

A Designated Accounts officer or another authorised member of the team will review the submitted information on a case-by-case basis, and a Director will conduct the final sign-off. Any customer or supplier who fails to pass the risk assessment will immediately have all transactions ceased pending review. If the review is unsatisfactory, the account will be closed indefinitely.

An accounts officer or another authorised member of the team will regularly review customer and supplier information, and a director will give the final sign-off.

All initial checks and further reviews will be documented in the customer or supplier file and maintained continuously. Check reminders should be logged into the accounting software and Outlook calendars.

The designated accounts officer will implement and maintain the DDCOC. All DDCOC training must be authorised by the Accounts officer or Directors, and any changes in staff will undergo full training on the DDCOC. Part of the DDCOC is to ensure day-to-day checks are in place to identify transactions that may lead to fraud or involve goods on which duty may have been evaded. Checks in purchase order processing and customer orders are two areas where daily checks are performed.