R v Green [2007] EWCA Crim 1248, [2007] All ER (D) 439 (May)
For the purpose of confiscation proceedings, where money or property is received by one defendant on behalf of several defendants jointly, each defendant is to be regarded as having received the whole of it.
It does not matter that proceeds of sale may have been received by one conspirator who retains his share before passing on the remainder; what matters is the capacity in which he received them.