Proceeds of crime

If confiscation proceedings did not involve a criminal charge, but were subject to the civil standard of proof, there was no reason in principle why confiscation should not be based on evidence that satisfied the civil standard, notwithstanding that it had proved insufficiently compelling to found a conviction on application of the criminal standard. Where a person had been acquitted in criminal proceedings and faced subsequent civil recovery proceedings, Art 6 of the European Convention on Human Rights applied only in circumstances where there was a procedural link between the criminal prosecution and the subsequent confiscation proceedings. Moreover, investigative costs incurred by a receiver and reimbursed by the Serious Organised Crimes Agency, including the reasonable remuneration of the receiver, were costs of, or incidental to, civil recovery proceedings.