AWRS Due Diligence Policy

AWRS Due Diligence Policy Behind This Wall Ltd, trading as Sonic Tonics Version 1.1 | March 2026 | AWRS Compliant

1. Purpose

Behind This Wall Ltd, trading as Sonic Tonics, operates as a producer and wholesaler of premium ready-to-drink beverages containing alcohol and CBD.

This due diligence policy ensures the company complies with the requirements of the Alcohol Wholesaler Registration Scheme (AWRS) and prevents the business from becoming involved in illicit alcohol supply chains.

The company is committed to trading only with legitimate suppliers and customers and maintaining full traceability of alcohol products.

AWRS Registration

Behind This Wall Ltd holds AWRS approval from HMRC. Our Unique Reference Number (URN) is XQAW00000123631 and will be displayed on all sales invoices to allow customers to verify our approval status via HMRC's online lookup service.

2. Scope

This policy applies to:

  • All suppliers of alcoholic ingredients
  • All wholesale customers purchasing Sonic Tonics products
  • Any distributors or logistics partners involved in alcohol supply
  • Company directors and employees responsible for procurement or sales

3. Supplier Due Diligence

Before purchasing alcohol or alcohol-containing ingredients, the business will verify suppliers by:

Identity Checks

The company will confirm:

  • Legal company name
  • Company registration number
  • VAT registration
  • Registered trading address

AWRS Status

Where suppliers are UK alcohol wholesalers, the company will:

  • Check AWRS registration through HMRC's online lookup service
  • Record the supplier's Unique Reference Number (URN)
  • Keep records of each verification check

AWRS approval status of all active suppliers will be re-verified at least annually, or whenever there is a material change in the trading relationship, to ensure continued compliance.

Commercial Credibility

The company will assess:

  • Length of time trading
  • Reputation within the drinks industry
  • Evidence of legitimate trading activity
  • Pricing structures consistent with market norms

Supplier Check Failure

If a supplier fails due diligence checks, or if their AWRS approval cannot be verified, the company will not proceed with the purchase. Where fraud is suspected, HMRC will be notified immediately via the Customs, Excise and VAT fraud reporting service.

4. Customer Due Diligence

Before supplying alcohol wholesale, Sonic Tonics will verify customers by:

  • Confirming business identity and trading address
  • Checking Companies House where applicable
  • Confirming the nature of the premises (e.g. bar, restaurant, retailer)
  • Recording contact details and trading history

Where customers are themselves alcohol wholesalers, the company will request and verify their AWRS Unique Reference Number (URN) via HMRC's online lookup service prior to supply. A record of this check will be retained.

Alcohol Licence Verification

For on-trade customers (bars, restaurants, licensed venues), a valid Premises Licence will always be verified and recorded prior to first supply. For other trade customers, relevant alcohol licences will be confirmed where applicable.

Customer Check Failure

If a customer fails due diligence checks, the company will not proceed with the supply. Where fraud is suspected, HMRC will be notified immediately via the Customs, Excise and VAT fraud reporting service.

5. Transaction Monitoring

The business will monitor trading activity to identify unusual behaviour, including:

  • Orders significantly larger than expected
  • Requests for cash transactions
  • Requests to deliver to non-business addresses
  • Requests inconsistent with typical trade patterns

Any suspicious activity will be investigated before orders are fulfilled.

If risk level raises real concern and checks lead to a suspicion of duty fraud, the company will contact the Customs Hotline.

6. Record Keeping

The company will maintain records of:

  • Supplier verification (including AWRS URN checks and dates)
  • Customer checks (including AWRS URN checks where applicable)
  • Purchase invoices
  • Sales invoices (displaying company URN)
  • Delivery records

Records will be retained for a minimum of six years.

7. Risk Awareness

The business recognises risks associated with alcohol duty fraud and illicit supply chains. To mitigate these risks the company will:

  • Purchase alcohol only from reputable, AWRS-approved suppliers
  • Avoid unusually discounted alcohol products
  • Maintain full production records
  • Ensure product traceability through batch coding

Note: The Alcohol Duty Stamps Scheme was discontinued on 1 May 2025. Any references to duty stamps in associated documents should be disregarded.

8. Responsibility

Responsibility for AWRS compliance sits with the company directors.

Operational staff involved in sales or procurement will be made aware of these due diligence procedures and are required to follow them.

9. Review

This policy will be reviewed annually or whenever there are significant changes to the business model, supply chain, or relevant HMRC guidance (including updates to Excise Notice 2002).

Additions and amendments from v1.0 are incorporated throughout. This policy has been reviewed against HMRC Excise Notice 2002 (Alcohol Wholesaler Registration Scheme).