Our Due Diligence


Bottle and Board Ltd (T/A Festa Wine) is firmly committed to conducting its business activities in strict accordance with applicable national, EU, and international legal frameworks. 

Our approach entails the following key aspects:

  • Thoroughly assessing the potential risks associated with alcohol duty fraud across our operational supply chains.
  • Implementing reasonable and proportionate measures within our daily trading operations to detect transactions that may present a risk of fraud or involve goods on which duty might have been evaded.
  • Establishing well-defined protocols for taking prompt and effective corrective actions in cases where the risk of fraud is identified.
  • Documenting the comprehensive checks that we intend to carry out and instituting a robust governance framework to ensure their consistent and accurate execution.
  • Being attuned to the "know your customer" obligations outlined in the 2017 Money Laundering Regulations, as they may be revised over time.

In the event of suspected fraud, we are committed to notifying the appropriate authority, HMRC, through our designated Lead Contact, Mr. Max Graham, who serves as our Director. It is important to note that customers not meeting our internal verification standards will be duly informed that their account opening request cannot be accommodated. Furthermore, instances of suspicious behaviour will be promptly communicated to HMRC, adhering to established timelines.

For transparency purposes, please be aware that we are not able to provide specifics regarding the timing, nature, or recipients of the reports we submit concerning suspicious behaviour.

Your trust and our commitment to integrity are of paramount importance to us.


The absence of a diligent approach in showcasing due care and attention could potentially lead HMRC to form the view that a business poses a risk to revenue and lacks the necessary credentials to be deemed "fit and proper" in accordance with excise legislation. Such an assessment could result in the imposition of restrictions or conditions, ultimately culminating in the revocation of authorisations, imposition of financial penalties, initiation of legal proceedings, and even the seizure of stock.


Bottle and Board Ltd (T/A Festa Wine) has thoughtfully formulated and recorded a series of processes designed to ensure the highest standards of operational integrity. 

These procedures encompass:

  • Verification of the identity of our trading partners.
  • Scrutiny of contractual terms to ensure alignment with our principles.
  • Thorough assessment of the origin and authenticity of goods involved in our transactions.
  • Evaluation of the financial stability of our trading counterparts.
  • Careful evaluation of the viability and credibility of the contemplated business deals.

Central to the execution of these processes is a judicious evaluation, always mindful of the 2017 Regulations. In each instance, we determine the requisite amount of information essential for validating the business relationship or specific transaction. Upon receiving information, we diligently undertake efforts to corroborate it through reference to credible independent sources whenever feasible.


This policy will be reviewed by the Business owners as required.


Bottle and Board Ltd (T/A Festa Wine) holds a steadfast dedication to combating alcohol fraud on a national scale. Our primary focus is on eradicating risk, and we maintain an unwavering commitment to upholding compliance with the Excise Due Diligence and AWRS regulations. We extend this commitment to our valued customers and suppliers, urging them to reciprocate by conducting similar checks on us.

It's worth noting that HMRC places an emphasis on conducting risk-based assessments. However, we understand that assessing all suppliers through this lens can be challenging for many of our customers. In recognition of this, we're pleased to provide the following information, which is intended to assist you in fulfilling your due diligence obligations effectively.

Trading Name: Bottle and Board Ltd (T/A Festa Wine)
Trading Address: Mathon Court, Mathon, West Malvern Rd, Malvern, WR135NZ
Trading Activity: Wholesaler of Wine, Beer & Spirits & direct delivery to customers through online website
Company number: 09386779
Date of Incorporation: 13 January 2015
VAT Number: 210326467
HMRC Deferment Number: NA
AWRS number: XQAW00000106164
WOWGR Excise ID: GBOG210326400
EORI : GB210326467000
Phone: 07786867679
Email: max@wearefesta.co.uk

With this information, checks can be carried out on the identity and financial health of the company through Companies House in the UK.

Company Structure

Festa Wine is a trading arm of Bottle and Board Ltd, a limited company and is a registered and incorporated entity under Companies House in the UK. Our current board of directors, along with contact details, our registered address, and annual accounts, can all be easily confirmed and validated through their online service. This transparent access underscores our commitment to accountability and legitimacy.

Bottle and Board Ltd (T/A Festa Wine) Supply Chain

Festa Wine exclusively partners with reputable enterprises as sources for our products. It's important to note that all our stock has undergone the requisite duty payment before departing our bonded warehouse located at LCB Creek Rd, Units 61-64, Creek Road, Barking, Essex, IG11 0JH.

Evidence of Duty Payment

Bottle and Board Ltd (T/A Festa Wine) ensures that all the stock we supply is duty paid, except in cases where it involves transfers between bonded warehouses. It's important to note that we do not provide customers with evidence of duty payment. Such information and corresponding evidence will solely be provided to HMRC upon their explicit request. Pertinent invoices will feature our Alcohol Wholesaler Registration Scheme number, which is XQAW00000106164.

Documents that We are Unable to Supply

We want to ensure the security of Bottle and Board Ltd (T/A Festa Wine) , our employees, and the Exchequer. For this reason, we are unable to provide certain documents due to their potential for misuse and fraud. 

These documents include:

  • Bank statements
  • Utility bills
  • Copies of directors' passports
  • Copies of directors' private address details
  • Blank invoices
  • Blank letterheads

We believe that this information addresses your needs in meeting your Excise Due Diligence requirements. If you have any inquiries regarding this matter, please feel free to reach out to us. Your understanding in this regard is greatly appreciated.


To facilitate the registration process for trading, Bottle and Board Ltd (T/A Festa Wine) will require the following documents from businesses:

  • A copy of the Incorporation Certificate
  • A copy of the VAT Certificate
  • Company bank details
  • Photo ID details of the owner, such as Passport or Driving License
  • A copy of a business utility bill (dated within the last three months)

Once these essential documents have been gathered, Festa Wine will initiate the necessary verification procedures before finalizing the account setup. Customers identified as posing a high risk will undergo additional inquiries. High-risk customers who are approved will undergo evaluations every three months, while all other customers will be subject to annual reviews.

For the convenience of our customers, we accept payment through card transactions or bank transfers. We prefer bank transfers for transactions, but also facilitate card payments for online sales. Please note that we do not accept cheques as a mode of payment.

Customers who do not meet our internal verification standards will be promptly informed that their account cannot be opened. Additionally, customers displaying suspicious behaviour will be promptly reported to HMRC, ensuring compliance with regulatory obligations.


As a dedicated participant in the Alcohol Wholesaler Registration Scheme (AWRS), Bottle and Board Ltd (T/A Festa Wine) is committed to conducting thorough due diligence assessments on partners within the alcoholic drinks supply chain. To ensure a transparent and compliant engagement, Festa Wine will require the following essential documents from wholesalers seeking to establish an account:

  1. Company Introduction: A comprehensive introduction detailing the nature of the wholesaler's business and the range of products offered.
  2. Payment Terms and Provisions: Clear payment terms, inclusive of a returns policy, insurance provisions, and specifics regarding the provisions under which goods are sold (e.g. ex-cellars, FOB, delivered).
  3. Company Bank Details: Accurate company bank information to facilitate seamless transactions.
  4. Company Details: Key company information, including:
  • Company Registration Number
  • VAT Registration Number
  • HMRC Deferment Number (if applicable)
  • WOWGR Number (if applicable)
  • Excise Registration Number
  • Warehouse Address
  • AWRS Number (URN)
  1. Proof of UK Duty Payment (if applicable): If the wholesaler is a UK duty paid supplier, copies of form W-5 or similar documents showing evidence of duty payment should be provided.

These documents are crucial in enabling Festa Wine to conduct meticulous due diligence checks and maintain compliance with the AWRS guidelines. We are committed to safeguarding the security and confidentiality of the information provided as we work towards a mutually beneficial partnership.

Once the supplier submits the aforementioned information, our appointed accounts officer or a qualified team member will diligently review the provided details. This assessment will lead to an evaluation of the overall risk associated with the supplier's profile. In the event that a supplier is categorised as high risk, further inquiries will be made, and if deemed necessary, on-site visits will be arranged. Any instances of suspicious retail pricing at unusually low levels or irregular trading patterns will be promptly reported to HMRC in adherence to our commitment to regulatory transparency. 

All high-risk suppliers will undergo re-evaluation every three months, while other suppliers will undergo an annual review.

The Festa Wine Due Diligence Code of Conduct (DDCOC) serves as our guiding framework, delineating fundamental principles and values that inform our decisions. It also directs us toward comprehensive processes and procedures that govern the acquisition and distribution of alcoholic products.

At the heart of the DDCOC lies the principle of "knowing your customer or supplier" and the associated commercial transactions. Recognising the pivotal role of every link in the supply chain, the DDCOC is designed to prevent engagement with any illicit customer or supplier. This policy ensures that all customers and suppliers undergo regular assessments, enabling the identification of any shifts in activities and the consequent appropriate actions.

Specific guidelines have been meticulously outlined for both customers and suppliers. These parties must supply the required documents and complete the associated questions, enabling Festa Wine to conduct a comprehensive risk assessment before opening any accounts. Only customers and suppliers that successfully pass the risk assessment will be eligible for trade engagement. It's important to note that Festa Wine exclusively collaborates with alcohol industry suppliers who accept payment through cheque or bank transfer. Cash payments are strictly prohibited.

The submitted information will be meticulously reviewed on a case-by-case basis by the designated accounts officer or an authorised team member. The final endorsement will be conducted by a Director. Should a customer or supplier fail to meet the risk assessment criteria, all transactions will be immediately halted pending a thorough review. If the outcome of the review is deemed unsatisfactory, the account will be indefinitely closed.

Regular reviews of customer and supplier information will be carried out by the designated accounts officer or another authorised team member. A Director will provide the final approval. All checks, both initial and subsequent, will be meticulously documented and maintained in the customer or supplier file on an ongoing basis. To ensure timely checks, reminders will be logged in our accounting software and Outlook calendars.

The implementation and maintenance of the DDCOC will be overseen by the designated accounts officer. Training related to the DDCOC must receive authorisation from the accounts officer or Directors. Any changes in staff will necessitate comprehensive training on the DDCOC. A fundamental aspect of the DDCOC involves embedding daily checks to identify transactions that might signal fraud or the involvement of goods on which duty may have been evaded. These checks are prominently integrated into the purchase order processing and customer order procedures, ensuring robust vigilance on a day-to-day basis.