Fah Mai Holdings Limited Due Diligence Policy / AWRS

WOWGR Excise ID: GBOG281021400
AWRS Unique Reference Number (URN): XFAW00000117099
DEPARTMENTAL TRADER REGISTRATION NUMBER: 281 0214 42 0001

(Fah Mai Holdings Limited referred to as FMH)

As a part of the new Alcohol Wholesaler Registration Scheme (AWRS) and Warehouses keepers and Warehoused Goods Regulations (WOWGR) FMH is required to conduct due diligence checks on partners involved in the supply chain for alcoholic drinks. Fah Mai Holdings Limited will require the following documents for a wholesaler to open an account to start trading and for providing non duty paid and duty suspended goods to FMH. The same stringent due diligence process will take place whether the relationship is that of a new wholesaler supplying FMH, or a distillery or broker supplying non duty paid goods, or if this is to be a new forward trading relationship with a wholesaler or retailer. FMH will be carrying out a detailed due diligence check on every new relationship. We will be checking that the people we are going to trade with pass certain credibility criteria.

Once we have connected with a new potential, we will do all web due diligence possible. We will check their web address, to make sure they have a website. If they do not have a website, we will check Google maps to see if the client’s location is visible if a physical visit is not possible. We will look at the history of their brand online, companies house checks to make sure they are filing annual returns and have no CCJ’s our court orders against them. If any of the following are found this will hinder their ability, if no reasonable explanation is provided, to proceed with us. We will google the company to determine if there is or is not any bad reports about them. Once we have done all of the online research possible, we will follow our onboarding process. In all cases we will take a face to face physical meeting at their location of business.

On Boarding process as follows:

  1. Speak with the client on the telephone and organize a zoom call if a face to face meeting is not possible. We will then discuss the history of the company, their reasons for wanting to supply our products and finding out their history.
  2. We will then request the following list of documentation.
    • Copy of Incorporation Certificate
    • AWRS and or WOWGR registration numbers will be required if applicable. (If we are supplying another wholesaler an active AWRS will be required, if we are buying duty suspended goods an active WOWGR registration certificate will be required.)
      We will put the AWRS company number into the AWRS lookup at https://www.gov.uk/check-alcohol-wholesaler-registration
      This will ensure the companies AWRS is still current.
    • Copy of VAT Certificate
    • Company Bank Details
      (If a company has not been operational for more than 2 years we will require bank statements showing trading activity and cash resources for invoice payments. If the company has a trading history and substantial tax returns that are visible online this may not be necessary.)
    • Owner/Director Photo ID details such as Passport or Driving License
    • Company structure document showing ownership and whether the company is a subsidiary of a parent company.
    • Company address proof for trading and registered address if different, Utility Bill and/or Bank Statement (Less than 3 months old)
  3. Confirmation of payment method will be ascertained as to how bills will be settled, whether it be by Cash/Card/Bank transfer will be the only methods for payment of invoices. The cash element will be capped at GBP250 PCM to manage the chances of money laundering.
  4. Trade references will be requested for a minimum of 2 other suppliers. We will contact the supplier and check there has been no unpaid invoices or payment issues.

Once Fah Mai Holdings Limited has collated this information, the necessary checks will be conducted before opening the account. Payment methods are Cash or Card or Bank Transfer only (Fah Mai Holdings Limited preferred method is bank transfers and Cards for online sale). Fah Mai Holdings Limited does not accept cheques. Cash payments have a cap of £250/month and are only applicable to onsite sale and can only be accepted under the Money Laundering Regulations.

Specific guidelines have been developed for customers and suppliers. All customers and suppliers must provide the required list of documents and completed questions for FMH to undertake a risk assessment before any account is open. FMH will only trade with a customer or supplier if they have passed the necessary risk assessment checks. FMH will only work with suppliers in the alcohol industry who accept payment by cheque or bank transfer.

Our Director Mr. Louis Haseman or another authorized member of the team will review the submitted information on a case by case basis and our head account control will conduct the final sign off. Any customer or supplier who fails to pass the risk assessment will immediately have all transactions ceased pending review. If the review is unsatisfactory, the account will be closed indefinitely.

Regular reviews of customer and supplier information will be conducted by Accounts officer or another authorized member of the team and the final sign off will be conducted by our Director Mr. Louis Haseman on an annual basis.

All checks and paperwork will be documented on our account opening form.

The process for documenting the sale the purchaser will produce a Purchase Order, to which an Invoice will be generated. Once paid the goods will be delivered along with a Delivery order and receipts generated automatically from our accounting.

Fah Mai Holdings Limited – CUSTOMER DUE DILIGENCE POLICY

For a retailer (Off License) to open an account:

In order for a business to register for trade, Fah Mai Holdings Limited will require the following documents:

Once Fah Mai Holdings Limited has collated this information, the necessary checks will be conducted before opening the account. Payment methods are Cash or Card or Bank Transfer only (Fah Mai Holdings Limited preferred method is bank transfers and Cards for online sale). Fah Mai Holdings Limited does not accept cheques. Cash payments have a cap of £250/month and are only applicable to onsite sale and can only be accepted under the Money Laundering Regulations.

For a wholesaler to open an account:

In order for a business to register as a wholesaler, Fah Mai Holdings Limited will require the following documents along with the completion of new account form:

Once the information has been gathered, the appointed officer or another qualified member of staff will complete a risk assessment. Any customers identified as high risk will undergo further questioning. High risk customers that are accepted will be evaluated every three months; all other customers will be reviewed on an annual basis.

All customers who do not pass the internal check will be notified that their account will not be opened and customers with suspicious behavior will be reported to HMRC in a timely manner.

For individuals only:

An account must be opened by providing following documents:

Delivery of products will only be done to Card’s registered name and address. Individual must be of the age of 18+.

Please note that all accounts type need to send the application form to admin@fahmaiholdings.com.

Fah Mai Holdings Limited – SUPPLIER DUE DILIGENCE POLICY

As a part of the new Alcohol Wholesaler Registration Scheme (AWRS), Fah Mai Holdings Limited is required to conduct due diligence checks on partners involved in the supply chain for alcoholic drinks. Fah Mai Holdings Limited will require the following documents for a wholesaler to open an account to start trading:

Once the supplier has sent the above information, the appointed accounts officer or another trained member of the team will review it. The overall risk of the supplier will be established. If the business is identified as a high-risk supplier, further questions will be asked and site visits will be conducted as appropriate. Any suspicious retail pricing at uneconomic levels or improper trading patterns will be reported to HMRC in a timely manner.

All high-risk suppliers will be reviewed every three months; all other suppliers will be reviewed on an annual basis.

Existing suppliers who are already supplying Fah Mai Holdings Limited at the date of this policy will need to provide Fah Mai Holdings Limited with the relevant documents (as above) to continue as a supplier. As with new suppliers, each supplier's risk will be established. Regular visits to the supplier’s premises will also be made by Fah Mai Holdings Limited representatives to verify business records.

Specific guidelines have been developed for customers and suppliers. All customers and suppliers must provide the required list of documents and completed questions for Fah Mai Holdings Limited to undertake a risk assessment before any account is open. Fah Mai Holdings Limited will only trade with a customer or supplier if they have passed the necessary risk assessment checks. Fah Mai Holdings Limited will only work with suppliers in the alcohol industry who accept payment by cheque or bank transfer. Cash payments are not permitted.

Our director Mr. Louis Haseman or another authorised member of the team will review the submitted information on a case-by-case basis and our head account control will conduct the final sign off. Any customer or supplier who fails to pass the risk assessment will immediately have all transactions ceased pending review. If the review is unsatisfactory, the account will be closed indefinitely.

Regular reviews of customer and supplier information will be conducted by Accounts officer or another authorised member of the team and the final sign off will be conducted by Our director Mr. Louis Haseman on an annual basis.

All initial checks and further reviews will be documented in the customer or supplier file and maintained on an ongoing basis. Reminders for checks should be logged onto the accounting software and google calendars.

All checks and paperwork will be documented on our account opening form.

The process for documenting the sale the purchaser will produce a Purchase Order, to which an Invoice will be generated. Once paid the goods will be delivered along with a Delivery order and receipts generated automatically form our accounting software Xero.

Please note that all account types need to send the application form to admin@fahmaiholdings.com and applicants must be over the legal drinking age in their jurisdiction of business, in the United Kingdom this is 18 years of age.

Important Note: All AWRS details will be found at www.gov.uk/guidance/the-alcohol-wholesaler-registration-scheme-awrs we will expect each and every supplier to check a box on our application to confirm they have read and understood the AWRS rules and regulations.