FHDDS40300 - record keeping and due diligence: acting on due diligence findings

(The Fulfilment Businesses Regulations 2018, regulation 10)

It will not be good enough for a fulfilment business to merely collect pieces of paper in order to meet the requirements of the scheme. The fulfilment business should also take account of what the due diligence is telling them.

The fulfilment business must notify HMRC where they know or have reasonable grounds to suspect that an overseas customer has not met a VAT or customs duty obligation. The fulfilment business should email HMRC at notificationofnoncompliance.fulfilmenthouse@hmrc.gov.uk (link

The approved person is required to inform HMRC in writing or by logging into their online FHDDS account of any changes to the information they provided at the time of registration.

There is more information on how to interpret the term ‘knew or had reasonable grounds to suspect’ in FHDDS26100.

If the fulfilment business knew or had reasonable grounds to suspect that an overseas customer has not met a VAT or customs duty obligation and continued with the transaction or arrangement they could be liable to a penalty, forfeiture of goods or criminal proceedings.

Penalties are set out in more detail at FHDDS50000.