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(»Ê¹ÚÌåÓýapp 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. »Ê¹ÚÌåÓýapp fulfilment business should also take account of what the due diligence is telling them.

»Ê¹ÚÌåÓýapp 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. »Ê¹ÚÌåÓýapp fulfilment business should email HMRC at [email protected] (link

»Ê¹ÚÌåÓýapp 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.

»Ê¹ÚÌåÓýappre is more information on how to interpret the term ‘knew or had reasonable grounds to suspectâ€� 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.