Crown Prosecution Service v Jennings [2008] UKHL 29, [2008] All ER (D) 177 (May)
A person's acts may contribute significantly to property being obtained without his obtaining it.
Orders for the confiscation criminal assets, or orders restraining the disposal of property pending the hearing of a confiscation order, may be made in respect of property which the person has actually obtained, not property he has merely helped others obtain.