R v Newman [2008] EWCA Crim 816, [2008] All ER (D) 266 (Apr)
A person obtained a benefit, pursuant s 76(4) of the Proceeds of Crime Act 2002, if he received property, even if he did not retain it, or if the property was in fact controlled by another on his behalf, or controlled by that other for him and the other person jointly.
If A arranged for property to be transferred to B, who was acting as his nominee and the property remained under A’s control, then A had obtained an interest in it, provided that there was control of it.
