Since 1st July 2005, when the excise Mutual Assistance Regulation 2073/2004 came into force, each Member State is legally required to provide a response to MA requests within 90 days of receipt. Except where requests are unreasonable you will be expected to act upon these requests as they are received, regardless of whether you consider the request to represent a risk. The UK Liaison Department in Glasgow will forward MA requests through to Risk Teams for immediate issue.
Where agreed, high-risk references will be issued directly to nominated officers and copied to Risk Managers and CRMs within LBS. Other references should be periodically batched and sent through to the Risk Team or CRM by the RFDT for risk analysis and appropriate action as part of regular assurance activity. Batching up references will help officers and risk teams to examine the activity of traders over a period of time, and identify potential high risk activity requiring further action to be implemented (e.g. Commissioners Directions requiring duty payment where imported goods are regularly re-exported within very short timescales).
Assurance events of this type may be very specific, but can be expected to involve full credibility challenges of traders and their supply chains. It is likely that Senior Officer (SO) Assurance Managers will be directly involved in the planning of these, as well as their delivery. National Assurance Projects will have the backing of the Alcohol Strategy Delivery Group (ASDG) and must be seen as a priority.
Occasionally, traders thought to pose a low risk will be selected for assurance activity. This will be done to test the risks within the wider trader population, and also to test the assumptions and information held within the risk matrix itself. Experience with alcohol traders has shown that high-risk traders will typically introduce previously unknown traders (or “clean skins”) into their supply chains. These traders often have no previous involvement with alcohol (sometimes hinted at by their trading names), and may have a reasonably good compliance history for VAT. Their VAT trade class on Departmental systems may well be unrelated to excise activity. These traders may then be used to create fictitious chains, to introduce diverted or smuggled alcohol into mainstream supply chains. These traders make the assurance of supply chains more complicated, and can also provide a safety barrier for high- risk traders between them and HMRC and, crucially, between them and any obvious liability to pay excise duty.