HMFSA5200 - 100% Movement guarantees: What primary legislation allows us to require 100% movement guarantees?

Customs and Excise Management Act 1979 s157 Bonds and security states:

“Without prejudice to any express requirement as to security contained in customs & excise Acts, the Commissioners, may, if they see fit, require any person to give security [{or further security) by bond, guarantee}] or otherwise for the observance of any condition in connection with Customs & Excise”.

Furthermore Notice 197 paragraph 12.5 indicates the following:

“In particular we may also ask traders to provide a guarantee which will cover the maximum amount of duty suspended in a single movement”.

Under existing law we are not able to stop movements being consigned to a tax warehouse, we are simply acting appropriately within our powers to try and address a proven high revenue risk.