FHDDS25300 - Policy and background: due diligence: acting on due diligence

It will not be good enough for an approved person to merely collect pieces of paper in order to meet the requirements of the scheme. The approved person must also take some action to check the information and act upon what the due diligence is telling them and, they must also:

• inform HMRC where they know or have reasonable grounds to suspect that a customer has not met a VAT or customs duty obligation. The fulfilment business should email HMRC at notificationofnoncompliance.fulfilmenthouse@hmrc.gov.uk.
• take steps to ensure that their overseas customer starts to comply with their VAT and duty obligations.

If the approved person knew or had reasonable grounds to suspect that a customer has not met a VAT or customs duty obligation and did not notify HMRC, they could be liable to up to a £3000 penalty.

There is more information at The Fulfilment Businesses Regulation 9, Regulation 10 and Regulation 11.