News From TTB: TEMPORARY VOLUNTARY DISCLOSURE PROGRAM FOR ALCOHOL BEVERAGE WHOLESALERS AND IMPORTERS TO ADDRESS UNREPORTED CHANGES IN CONTROL OR PROPRIETORSHIP
July 7, 2019
Through December 31, 2019, TTB is offering a temporary voluntary disclosure program (see Industry Circular 2019 – 2) to address the significant number of wholesalers and importers of alcohol beverages who have undergone a change in control (a change in who controls a business) or change in proprietorship (a change in the person or entity that owns a business) but failed to file a new permit application within 30 days of the change, as required by law.
This temporary program provides a streamlined approach that allows eligible wholesalers and importers to simultaneously voluntarily disclose the unreported changes in control or proprietorship and file an application for a new permit while benefiting from the enforcement discretion described in section 6 of Industry Circular 2019 – 2.
This Temporary Voluntary Disclosure Program is open to industry members who:
. Hold a TTB permit only as a wholesaler and/or importer of alcohol beverages and no other TTB permit, notice, or registration;
. Self-identify a change in control or proprietorship and voluntarily disclose it by following the instructions provided in Industry Circular 2019 – 2; and
. Submit all required documentation described in Industry Circular 2019 – 2 no later than December 31, 2019.
Industry members with TTB permits, notices, and registrations other than or in addition to wholesaler and importer permits, while not eligible for this temporary program, are encouraged to use the existing Voluntary Disclosure Program described under Industry Circular 2004 – 5 to come into compliance regarding unreported changes in control and proprietorship. Industry members who have a compliance issue other than unreported changes related to their permit may report those violations through the existing Voluntary Disclosure Program.
Read Industry Circular 2019 – 2 for the full details regarding this temporary voluntary disclosure program, as well as the instructions for how to submit the required documentation.
PLEASE NOTE that eligible industry members who have already submitted a voluntary disclosure regarding an unreported change in control or proprietorship should also follow the instructions outlined Industry Circular 2019 – 2.