CCPG26260 - Warning letter: considering whether to issue a warning letter: considering any previous action taken

When completing the Customs Penalty Action Checklist (CPAC), it is important that the compliance officer considers the trader’s

• level of experience (for example, is this their first intervention?) and
• compliance history (for example, have they previously received education and advice).

This is important because

• if we have not taken any previous action as it is the first time a trader has encountered this process, then providing education may be more appropriate than issuing a Civil Penalty Warning Letter (CPWL),
• if the previous action was more than two years ago we will treat this as a new contravention or
• if we have already issued a CPWL about a broadly similar contravention within the last two years then we should issue a penalty, rather than considering a further warning letter.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

Once we have checked and dependent on what has been done previously, we may consider proceeding with CPWL action.