Sentence – Confiscation order. The Court of Appeal, Criminal Division, on a reference brought by the Criminal Cases Review Commission (CCRC), dismissed the defendant's second appeal against a confiscation order made against her in 2006. Among other things, in considering the Supreme Court decision of R v Waya ([2013] 1 All ER 889), there was nothing from the available information from which it could be inferred that the amount of the confiscation order, in the sum of £100,000, had been in any way disproportionate. Further, Lord Thomas CJ provided guidance on the essential duty of the CCRC to consider the law in relation to 'substantial injustice' when considering whether to refer a sentencing case to the Court of Appeal, Criminal Division.