CCPG30520 - International Trade officers operational process: penalty notice: authorisation of penalties: who an authorising officer may be and what action they should take
THIS GUIDANCE IS FOR INTERNATIONAL TRADE OFFICERS ONLY
»Ê¹ÚÌåÓýapp Authorising officer is the Compliance manager.
»Ê¹ÚÌåÓýapp authorising officer will authorise the issue of the penalty by completing the bottom of the Customs Penalty Action Checklist (CPAC).
Before authorising a penalty the authorising officer should:
- Check that they have received all of the relevant paperwork
- Decision-making template
- CPRAF
- Completed Penalty Notice
- All supporting documents
- Check that the Penalty is accurate in all respects
- Have the correct trader particulars been included
- Has the correct legislation been applied
- Do you agree that the information recorded on the decision making sheet confirms that penalty action is the best course of action to improve compliance
- Have you checked that when deciding the level of penalty, the officer has taken account of the circumstances surrounding the contravention
- Have they established whether there was either a reasonable excuse or mitigating factors that they should have considered
- Have they identified if the trader has taken or is in the process of taking remedial action to improve compliance
- Have they incorporated RTBH into their decision to issue penalty
All of these factors must be considered to ensure we have a consistent approach to charging penalties. Remember the penalty must be both reasonable and proportionate to both the volume and circumstances surrounding the contraventions.