Sanam v National Crime Agency: [2015] EWCA Civ 1234; [2015] WLR (D) 495
‘There was no basis for concluding that a civil recovery order obtained by the National Crime Agency pursuant to Part 5 of the Proceeds of Crime Act 2002 in respect of property derived from unlawful conduct would violate the rights of an innocent former wife of the criminal under article 1 of the First Protocol to the European Convention for the Protection of Human Rights and Fundamental Freedoms, even though she would be left without any assets if a recovery order was made.’
WLR Daily, 2nd December 2015
Source: www.iclr.co.uk
