Criminal law – Proceeds of crime. The appellant's appeal against a confiscation order made against him failed. The Court of Appeal, Criminal Division, held that the order had not been disproportionate, and that the circumstances had justified the judge's conclusion. The possibility of removing from a defendant by way of confiscation a sum larger than might represent his net proceeds of crime was consistent with the Proceeds of Crime Act 2002's objective, and represented a proportionate means of achieving it. The legislation was directed towards the proceeds rather than the profits of crime.