Proceeds of crime – Criminal property. For the purpose of s 6 of the Proceeds of Crime Act 2002, the benefits from a re-mortgage were likely to be the proportion of the increased value of the property represented by the amount of the re-mortgage, plus any rent earned since the re-mortgage, on a proportionate basis. To that extent, the Court of Appeal, Criminal Division, dismissed the defendant's appeal against the judge's confiscation order, although the judge had erred in his finding on the benefit sum in one respect.