Intrepid Wines Ltd – Due Diligence Policy 2025
Policy Statement
Intrepid Wines Ltd is committed to conducting all business in full compliance with UK, EU, and international laws, including excise and AWRS regulations. We aim to:
- Assess and mitigate risks of alcohol duty fraud across our supply chain.
- Implement reasonable measures to detect suspicious transactions or goods with unpaid duty.
- Take prompt corrective actions where fraud risk is identified.
- Maintain robust governance and document all due diligence checks.
- Comply with “know your customer” obligations under the 2017 Money Laundering Regulations.
Suspected fraud will be reported to HMRC via our Director, Henry Clark-Jones. Customers or suppliers failing verification standards will be informed that accounts cannot be opened, and suspicious activity will be reported to HMRC. Specific reporting details are confidential.
Consequences of Non-Compliance
Failure to demonstrate due diligence may result in HMRC deeming the business “not fit and proper,” potentially leading to:
- Restrictions or conditions on trading
- Revocation of authorisations
- Financial penalties or legal proceedings
- Seizure of stock
Processes
Our due diligence processes include:
- Verification of trading partners: Identity, incorporation, VAT, AWRS, and bank details
- Contract review: Ensure alignment with company principles and excise compliance
- Goods verification: Confirm origin, authenticity, and duty status
- Financial assessment: Evaluate stability and credibility of partners
- Deal assessment: Confirm commercial rationale and fairness
All checks are supported by credible independent sources where possible, and the level of scrutiny is proportional to risk.
Supply Chain Commitment
Intrepid Wines only sources products from reputable suppliers.
All stock is duty paid prior to leaving our bonded warehouse at London City Bond, Unit 2, Gateway Road, Barton Under Needwood, Staffordshire, DE13 8FL.
Restricted Documents: To prevent fraud, we do not provide:
- Bank statements
- Utility bills
- Directors’ passports
- Blank invoices or letterheads
Trade Customer Due Diligence
To open a trade account, customers must provide:
- Incorporation certificate
- VAT certificate
- Company bank details
- Photo ID of owners (e.g. driving license)
High-risk customers undergo additional checks and quarterly reviews; low-risk customers are reviewed annually. Payment accepted via bank transfer or card; cash and cheques are not accepted.
Supplier Due Diligence
Suppliers must provide:
- Company introduction and product range
- Payment terms and conditions (including insurance, returns, delivery)
- Company bank details
- Key company information: registration number, VAT number, AWRS number, warehouse address
Suppliers are risk-assessed; high-risk suppliers undergo further inquiries, potential site visits, and quarterly reviews. Only compliant suppliers passing due diligence will be engaged. Cash and cheque payments are strictly prohibited.
Monitoring & Governance
All checks, approvals, and communications are documented and stored securely.
High-risk customers and suppliers are re-evaluated quarterly; others annually. The Director oversees compliance; appointed staff execute day-to-day due diligence.
Traffic light system
Our due diligence approach uses a traffic light system.
- Suppliers or customers deemed risky (red) are reviewed more frequently (likely quarterly) and thoroughly.
- Those who are trusted in principle though await verification by documentation and/or track record of reliability are categorised as amber and will undergo a full reinspection at 6 month intervals.
- Those with a proven track record and credentials (green) are low risk and are reinspected annually.