Sentence – Confiscation order. The Court of Appeal, Criminal Division, allowed the defendant's appeal against the imposition of a compensation order and a confiscation order, following his conviction for fraud, where the figure representing the compensation order had also been included in the confiscation order. The court gave guidance on points to be borne in mind for future cases in the Crown Court where the prosecution sought both a compensation order and a confiscation order in circumstances where s 13(5) and (6) of the Proceeds of Crime Act 2002 were not applicable.