R v Solanki and Another

Court of Appeal (Criminal Division) [2020] EWCA Crim 47, Before Lord Justice Singh, Mr Justice Spencer and His Honour Judge Leonard QC (Sitting as a Judge of the Court of Appeal, Criminal Division), 24 January 2020

Proceeds of Crime Act 2002 - Criminal property - Jury directions - Underlying offences - R v Brown (1984) 79 Cr App R 115.

Following a trial in the Crown Court at Harrow, the two appellants were convicted of an offence under section 328(1) of the Proceeds of Crime Act 2002 ("POCA"), which states, "[A] person commits an offence if he enters into or becomes concerned in an arrangement which he knows or suspects facilitates (by whatever means) the acquisition, retention, use or control of criminal property by or on behalf of another person." The first appellant was sentenced to eight years' imprisonment and disqualified from acting as a director for a period of 10 years. The second appellant was sentenced to six years' imprisonment.