Proceeds of crime – Civil recovery of proceeds of unlawful conduct. The claimant National Crime Agency sought a civil recovery order, under the Proceeds of Crime Act 2002, over eight properties, the proceeds of rental income, and English and Luxembourg bank accounts. The Queen's Bench Division held that, with the exception of one property, the assets were recoverable, as they had been acquired through unlawful conduct, namely, drug dealing, money laundering or VAT fraud.