Sentence – Confiscation order. A confiscation order under s 156 of the Proceeds of Crime Act 2002 could be made by a Crown Court in circumstances where a defendant was convicted in proceedings before that Crown Court of an offence or offences which were committed before 24 March 2003. The Supreme Court so held, despite the stipulations of the Proceeds of Crime Act 2002 (Commencement No 5, Transitional Provisions, Savings and Amendment) Order 2003.