Proceeds of crime – Unlawful conduct. The second defendant objected to the inclusion of the matrimonial home in the claimant National Crime Agency's application for a civil recovery order (CRO) in respect of seven properties, four bank accounts and a Rolex watch. The Queen's Bench Division held that there was an overwhelming case against the first defendant for misconduct consisting of drug-dealing, money laundering and mortgage fraud, such that all the property was recoverable. With respect to the matrimonial home, the statutory exception to its inclusion in the CRO in s 266 of the Proceeds of Crimes Act 2002 had not been made out.