Agave Artisan is a responsible and transparent alcohol business committed to preventing alcohol duty fraud and operating in full compliance with the Alcohol Wholesaler Registration Scheme (AWRS) as regulated by HM Revenue & Customs (HMRC).

We recognise our obligation to ensure that all alcohol purchased and supplied through our business originates from legitimate, duty-paid sources. We are dedicated to maintaining a clean and compliant supply chain and to supporting HMRC’s objectives in combating illicit alcohol trading.

We confirm that Agave Artisan is registered under AWRS and that we will only trade alcohol with other verified and compliant businesses.

2. Due Diligence Procedures

To ensure compliance, Agave Artisan has established a comprehensive due diligence framework based on HMRC’s “Fit and Proper” guidance.

Our internal due diligence procedures apply to all trading relationships and include:

• Verifying supplier and customer AWRS registration via the HMRC online database.

• Reviewing company incorporation details, VAT registration, and business addresses.

• Assessing the financial and trading history of all partners.

• Checking for unusual trading patterns, such as inconsistent pricing or delivery practices.

• Retaining digital records of all checks, reviews, and verification evidence.

No trading activity proceeds until all due diligence checks are satisfactorily completed.

3. Supplier Verification

Before purchasing alcohol, Agave Artisan confirms that each supplier:

• Holds a valid AWRS Unique Reference Number (URN).

• Appears as “Registered” on HMRC’s AWRS Registered Traders List.

• Provides appropriate business documentation (e.g., company number, VAT certificate, and invoicing details).

• Maintains consistent and legitimate trading activity.

Verification includes recording:

• The supplier’s AWRS number and verification date.

• Evidence of the HMRC database check (e.g., screenshot or confirmation record).

• Notes on the supplier’s risk level and ongoing monitoring.

All suppliers are re-verified at least annually, or sooner if trading conditions change.

4. Customer Risk Assessment

Agave Artisan operates a structured risk-based assessment for all trade customers.

Each customer undergoes an initial review before trading begins, which includes:

• Verification of business identity, address, and VAT number.

• Confirmation of AWRS registration (if applicable).

• Review of the customer’s licensing credentials and intended use of goods.

• Evaluation of order volumes, payment methods, and purchasing behaviour.

Customers are assigned a risk rating (low, medium, or high) based on the above factors.
High-risk customers may be asked to provide additional documentation or trade references.

If any customer displays suspicious behaviour - such as unusually low pricing, cash-only payments, or refusal to provide details - trade is immediately suspended and HMRC is notified.

5. Reporting Suspicious Activity

Agave Artisan is committed to cooperating with HMRC and promptly reporting any suspicious activity, fraud, or evidence of duty evasion.

All concerns are reported within five (5) working days of identification via the official HMRC channels:

HMRC Fraud Hotline
🔗 https://www.gov.uk/report-tax-fraud

We maintain a written log of all reports and communication with HMRC.

6. Documentation and Record Keeping

All due diligence checks, verification results, and trading records are documented electronically and securely stored in our internal compliance system.

We retain:

• Supplier and customer verification evidence.

• Copies of invoices, delivery notes, and correspondence.

• Risk assessments, audit logs, and verification results.

All documentation is:

• Digitally stored and backed up securely.

• Retained for a minimum of six (6) years.

• Made available to HMRC or enforcement authorities upon request.

7. Staff Awareness and Training

All relevant employees at Agave Artisan receive regular training on:

• AWRS regulations and HMRC compliance expectations.

• How to perform due diligence and verification checks.

• Identifying suspicious behaviour and reporting procedures.

Training records are maintained electronically and updated annually or following any regulatory changes.

8. Policy Review

This AWRS Policy is reviewed annually, or sooner if there are changes to HMRC guidance, licensing laws, or our trading practices.

Next review due: October 2026

9. Declaration

Agave Artisan affirms its commitment to:

• Upholding all obligations under the Alcohol Wholesaler Registration Scheme.

• Trading only with verified, compliant, and legitimate businesses.

• Preventing alcohol fraud and duty evasion through robust due diligence.

• Maintaining transparent and responsible business practices.

AWRS Number: XSAW00000121145
Registered Business: Agave Artisan (Trading as The Naked Margarita)
Address: 82A James Carter Road, Mildenhall, IP28 7DE
Email: hello@agaveartisan.co.uk