England and Wales Case Law

Director of Public Prosecutions v Boureanu

Director of Public Prosecutions v Boureanu [2026] EWCR 1 (16 January 2026)

The Crown Court held that a Romanian confiscation order remained enforceable despite no custodial sentence, and appointed a receiver over funds in UK accounts.

• Enforcement of foreign confiscation orders
• Interpretation of 'conviction' under proceeds of crime act 2002 (external requests and orders) order 2005
• Appointment of receiver
• Mutual legal assistance
• Asset recovery
• Proceeds-of-crime

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The Director of Public Prosecutions v Christian Alexandru Boureanu

The Crown Court held that a Romanian confiscation order followed a conviction and appointed a receiver to enforce it against funds held in UK accounts.

• Enforcement of external confiscation orders
• Interpretation of 'conviction' under proceeds of crime act 2002
• Mutual legal assistance
• Appointment of receivers
• Asset recovery
• External-confiscation-orders

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JSC Commercial Bank Privatbank v Igor Valeryevich Kolomoisky & Ors

The High Court entered judgment for PrivatBank, fixed principal and interest sums, awarded indemnity costs, and refused permission to appeal and a general stay.

• Fraud
• Asset recovery
• Compound interest
• Sanctions
• Costs (indemnity basis)
• Worldwide freezing orders

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Director of the Serious Fraud Office v Schools

Director of the Serious Fraud Office v Schools [2025] EWHC 1146 (Admin) (13 May 2025)

The High Court made an unexplained wealth order and interim freezing order over Claire Schools’ property, finding insufficient lawful income and risk of dissipation.

• Unexplained wealth orders
• Interim freezing orders
• Asset recovery
• Fraud
• Confiscation proceedings
• Unexplained-wealth-order

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National Crime Agency v Yaqub Younis & Anor

The respondents failed to comply with the unexplained wealth order without reasonable excuse, engaging the statutory presumption that the properties are recoverable. There is a good arguable case that the properties are proceeds of unlawful conduct, and there is a real risk of dissipation. The statutory and discretionary requirements for a property freezing order are satisfied.

Source excerpt

• Property freezing order
• Unexplained wealth order
• Money laundering
• Mortgage fraud
• Asset recovery

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National Crime Agency v Younis & Anor

National Crime Agency v Younis & Anor [2023] EWHC 2477 (Admin) (14 September 2023)

The High Court granted the NCA a final property freezing order over 14 properties, finding non-compliance with an unexplained wealth order and a good arguable case of recoverable property.

• Proceeds of crime
• Property freezing orders
• Unexplained wealth orders
• Money laundering
• Asset recovery
• Property-freezing-orders

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Hyde & Anor v Djurberg

Hyde & Anor v Djurberg [2022] EWHC 1534 (Ch) (06 May 2022)

The High Court granted trustees a search and seizure order under s.365 Insolvency Act 1986 after finding non-compliance, dissipation risk, and the need for safeguards.

• Search and seizure
• Trustee duties
• Bankrupt's obligations
• Asset recovery
• Mental health considerations
• Bankruptcy

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ADRIAN HYDE & Anor v MYCK DJURBERG

The High Court granted trustees a search and seizure order under s.365 Insolvency Act 1986, finding a real risk of dissipation and destruction of estate assets and records.

• Search and seizure
• Trustee powers
• Bankrupt's duties
• Mental health in bankruptcy
• Asset recovery
• Insolvency

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Kazakhstan Kagazy Plc & Ors v Zhunus & Ors

Kazakhstan Kagazy Plc & Ors v Zhunus & Ors [2021] EWHC 3462 (Comm) (21 December 2021)

The High Court held that assets acquired through a fraud on Kazakhstan Kagazy were traceable, granted section 423 relief, and made final charging orders.

• Tracing
• Asset recovery
• Section 423 insolvency act 1986
• Charging orders
• Breach of fiduciary duty
• Limitation periods

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Varma v Atkinson & Anor

Varma v Atkinson & Anor [2020] EWCA Civ 1602 (27 November 2020)

The Court of Appeal dismissed Mr Varma’s appeal against contempt findings, holding that new evidence did not undermine them and intent was not required for liability.

• Contempt of court
• Breach of fiduciary duty
• Asset recovery
• Freezing orders
• Knowing receipt
• Misfeasance

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