by 
Recordkeeping
As a consultant for distilled spirits, I like to use an Iceberg metaphor to describe your compliance requirements. The tip of the iceberg represents monthly Reports of Operations – these require you to transmit a summary of your operations each month. The bulk of the iceberg lies below the surface, less visible: it represents your internal records, which sum up and flow through into monthly reports.
If you approach your recordkeeping with Reports in mind, you will miss a great deal of detail that the TTB requires you to track, including around 60 separate Daily Records, depending on your operations and flows. If you “record only to report”, you’ll likely run into issues when asked to substantiate the numbers on your reports (and that will happen at some point). If you cannot substantiate your figures, it can lead to TTB finding a violation and potentially interest, penalties and back taxes.
Distillery Management Software, like DISTILL x 5, takes the guesswork out. We’ve already done the hard work of figuring out how to generate the 60 required Daily Records; you simply enter your transactions in human-readable form using a graphical interface, and the software takes care of the rest. Since both your internal records and your monthly reports (sent to TTB) are generated out of the same base data, there is little chance for them to disagree. This, in turn, helps speed your way through audits.
Accurate Reporting
Certain tasks are better handled by humans, and others, by computers. Adding up a bunch of numbers and ensuring data consistency is difficult for humans, but easy for software. You can avoid the risk of imbalanced or incongruent report data using software like DISTILL x 5. Where humans transpose digits or misplace decimal points, software doesn’t skip a beat.
The other key piece in this puzzle is our Pay.gov Browser Extension. This free part of your software subscription takes care of automatically copying report data from DISTILL x 5 to Pay.gov, in a single click. Since data is transferred behind the scenes, there’s no chance of making a manual data entry error.
Even a minor report issue requires you to file amended reports, and frequent report issues will throw up a “red flag” at TTB and potentially cause further investigation. Fx5 helps you stay on TTB’s good side. You don’t want to know what it’s like to be on their bad side.
Nudges Towards Compliant Operations
The Code of Federal Regulations is full of traps for the unwary. One of my favorites involves barrels of Bourbon. You can mix (mingle) barrels of bourbon from different vintages and even different distilleries, and it still qualifies as Bourbon Whiskey. However, if one of the barrels was originally distilled in a different state, then mixing these barrels as described would constitute blending (not mixing/mingling) and would result in a product that qualifies as “A blend of straight bourbon whiskies”.
DISTILL x 5 has built-in guardrails to prevent you from mixing unlike spirit types in Storage, which can help you avoid this particular trap. There are many other compliance-oriented features to help you, including restrictions around transfers between liquid accounts and prompts to gauge at the required intervals. Thanks to these features, you can rest easy, knowing that your operations are compiant. The alternative? You could be faithfully recording illegal operations, thinking that you’re being compliant!
