Proceeds of crime – Confiscation order. High Court of Justiciary: Refusing an appeal by an appellant who pled guilty to a charge of formulating a fraudulent scheme whereby HMRC were induced to pay to claimants £50, 981 not due to them, and of which she received £15,294, the court held that the sheriff had not erred in making a confiscation order in terms of the Proceeds of Crime Act 2002 in which the appellant's benefit from her criminal conduct was identified as £50, 981 rather than £15,294.