AG v Smith & Cochrane (Royal Court : Hearing (Criminal) : Le Cocq : Saisie) [2025] JRC 256 (9 October 2025)

judgment the bailiff: Introduction 1. On 27 February 2025 this Court sat to consider an application by the Attorney General to vary the Saisie Judiciaire in respect of the realisable property of Gerald Martin Smith ("Mr Smith"). On that occasion the Court granted the application with reasons to follow. These, in brief, are those reasons.

2. On 20 May 2005, Wilkie J, sitting at the High Court of Justice, Queen's Bench Division (Administrative Court), issued a restraint order against Mr Smith in respect of his realisable property held in several jurisdictions for the purposes of satisfying any Confiscation Order that might be made in connection with criminal proceedings commenced against him ("the Restraint Order"). Dr Gail Alison Cochrane ("Dr Cochrane") was named as a third party to the Restraint Order. The Restraint Order was subsequently varied on 13 July and 22 November 2005, 6 February and 2 November 2006 and the 18 July 2008. It was also subject to further variations as follows - by Popplewell J on 23 May 2016, by Ousley J on 30 November 2016, by Jeremy Baker J on 19 December 2016, by Popplewell J on 25 May 2017. More recently it was further varied on 29 July 2020 by Foxton J and further varied by Andrew Baker J on 20 May 2022.

3. On 24 April 2006, Mr Smith pleaded guilty to nine Counts of theft and one Count of false accounting.

4. On 26 May 2006 a Saisie Judiciaire was made against the realisable property of Mr Smith under the Proceeds of Crime (Jersey) Law 1999 ("the 1999 Law"), as modified and included within the Third Schedule to the Proceeds of Crime (Designated Countries and Territories) (Jersey) Regulations 1999 ("the 1999 Regulations"). Paragraph (2) of the Court's Order authorised the Viscount to take possession of all the realisable property held by Mr Smith in the Island, whether movable or immovable, vested or contingent and to manage or otherwise deal with the same in accordance with the Court's directions pending further Order. The Saisie was varied under the 1999 Law as modified and included in the Schedule to the Proceeds of Crime (Enforcement of Confiscation and Instrumentalities Forfeiture Orders) (Jersey) Regulations 2008 ("the Modified 1999 Law").

5. On 11 September 2006 at Cambridge Crown Court, Mr Smith was sentenced to 8 years' imprisonment.

6. On 13 November 2007, His Honour Judge Roberts, sitting at the Inner London Crown Court, determined that Mr Smith had benefited from his criminal conduct in the sum £40,956,911 and ordered him to pay that sum within 12 months (in default of which it was ordered he should serve a term of eight years' imprisonment) ("the Confiscation Order"). In addition, Compensation Orders in favour of Izodia Plc in the sum of £5,288,119 and the Royal Bank of Scotland International in the sum of £21,350,000 were made. Pursuant to section 72(7) of the Criminal Justice Act, 1988, the Court further ordered that the Compensation Orders should be paid from any sums recovered under the Confiscation Order.

7. On 7 April 2008 following an application by the Director of the Serious Fraud Office ("SFO"), Owen J sitting at the High Court of Justice, Queen's Bench Division (Administrative Court) made a Receivership Order, originally appointing Mr Finbarr O'Connell and Mr Jeremy Outen of KPMG LLP as Enforcement Receivers ("the 2008 ERO").

8. On 29 May 2013 David Standish and John Milsom (then of KPMG LLP) now of Interpath Limited ("the Receivers") were appointed over the realisable property of Mr Smith in their place. The appointment requires the Receivers to take possession of and realise Mr Smith's realisable property for the purposes of satisfying the Confiscation Order.

9. Dr Cochrane did not accept that certain items of property over which the Receivers had been appointed constituted Mr Smith's realisable property. Accordingly, provision was made in the 2008 ERO for the claims of Dr Cochrane and other third parties named therein to be adjudicated (if not resolved by agreement) 10. On 23 July 2008, the Proceeds of Crime (Enforcement of Confiscation Orders) (Jersey) Regulations 2008 ("the 2008 Regulations") were repealed and replaced the 1999 Regulations.

11. On 16 March 2009, the Receivers and Dr Cochrane entered into a Consent Order before the High Court of Justice (Queen's Bench Division, Administrative Court). The Consent Order provided ( inter alia ) for certain assets subject to the Saisie and under the jurisdiction of the Royal Court to be sold and for certain payments to be made out of the proceeds of sale.

12. On 1 February 2010, the Attorney General received from the United Kingdom Central Authority at the Home Office a Request seeking registration in Jersey of the Confiscation Order.

13. On 25 March 2010, this Court determined that the Confiscation Order made by His Honour Judge Roberts was an External Confiscation Order ("ECO") as defined by Article 1(1) of the Modified 1999 Law and that it was clear from the Request received from the United Kingdom Central Authority that the requirements for registration of an ECO set out in Article 39 of the Modified 1999 Law were met in that: (i) an ECO was in force and was not subject to appeal (thus satisfying subparagraph (1)(a) of Article 39 of the Modified 1999 Law); (ii) Mr Smith had appeared at the confiscation proceedings (thus satisfying sub paragraph (1)(b) of Article 39 of the Modified 1999 Law); and (iii) enforcing the Confiscation Order in the Island would not be contrary to the interests of Justice (thus satisfying sub paragraph (1) (c) of Article 39 of the Modified 1999 Law).

14. Accordingly, this Court ordered that the Confiscation Order made on the 13 November 2007 in respect of the realisable property of Mr Smith be registered pursuant to paragraph (1) of Article 39 of the Modified 1999 Law and that the Viscount be authorised (pursuant to Articles 17 and 20 of the Modified 1999 Law) to realise the realisable property held by Mr Smith in the Island.

15. On 18 December 2013, the Viscount brought a Representation to the Court which confirmed that Dr Cochrane had made various proposals to purchase the unsold assets of Mr Smith (as at that date only four motor vehicles had been sold) and sought authorisation to accept offers from Dr Cochrane as follows: · £2,850,000 for Steephill and Bodega Limited; · £300,000 for the art collection and the wine collection; · an amount to be confirmed of 50% of the Viscount's fees and costs of the upkeep and maintenance of Steephill; and · the remaining two motor vehicles to be included in the sale.

16. The Court Ordered that the Saisie was to be discharged in relation to Bodega Limited, Steephill, the art collection, the wine collection and the motor vehicles upon payment by Dr Cochrane to the Viscount of the sums outlined in Dr Cochrane's offer.

17. On 24 January 2014, the Court Ordered that the Saisie in relation to Bodega Limited, Steephill, the art collection, the wine collection and the motor vehicles be discharged but that in all other respects it remains in force.

18. On 23 May 2016, the United Kingdom Restraint Order was further varied following application by the Serious Fraud Office on an urgent expedited basis. The SFO sought to vary the terms the Restraint Order to restrain Dr Cochrane, SMA Holdings Limited (a company incorporated in the Marshall Islands) and Mr Smith from dealing with the assets listed in Schedule 1. The Restraint Order was limited in value to £67,190,681.11. The purpose of this application was to preserve these assets so that would be available to satisfy the original Confiscation Order made against Mr Smith.

19. On 24 November 2016 the Saisie was varied by this Court. A declaration was to be sought under the Bankruptcy (Désastre) (Jersey) Law 1990 , in relation Orb a.r.l. and Dr Cochrane. On the same day as the variation, Dr Cochrane was placed en désastre by the Royal Court (see In the matter of the Désastre of Dr Gail Cochrane [2024] JRC 043 ).

20. The factual and legal background to the November variation was complex but, the essential justification was that Dr Cochrane had procured the transfer to herself of substantial property, some of which is in Jersey, to hold as a nominee from Mr Smith. It was the position of the SFO that such properties had either been purchased with, or had monies invested in them which originated from the proceeds of what was known as the Isle of Man Settlement, received by Dr Cochrane or her company SMA (a company incorporated in the Marshall Islands of which she was the registered owner and which Mr Smith controlled at the time) and that Dr Cochrane received such monies in her capacity of Mr Smith's nominee. In this regard, particular emphasis was placed on the judgment of Popplewell J in ORB a.r.l & Ors v Ruhan & Ors [2016] EWHC 850 (Comm) at [16]. It was the SFO's case that Mr Smith had an interest in those assets or alternatively that the transfer of them to Dr Cochrane may amount to gifts caught by both the English Criminal Justice Act 1988 and the 1999 Law.

21. As a consequence of the application the Saisie was varied at paragraph (i) (7). It specified that realisable property of Mr Smith also included: "any other property held by Dr. Cochrane or Orb a.r.l., for or on behalf of, as nominee for or for the benefit of Dr. Gerald Martin Smith ("Smith")" 22. The amount currently outstanding under the confiscation order (including interest) exceeds £81.9 million. The current application 23. On 14 June 2024, the Attorney General served on the Respondents his application for a variation of the Saisie Judiciaire pursuant to Article 16 (6) (a) and 16 (7) of the Modified 1999 Law.

24. The variation sought is limited in nature. It allows Dr Cochrane to deal with property she is otherwise prohibited from dealing with under the terms of the Saisie Judiciaire referred to above.

25. Dr Cochrane would be permitted pursuant to the variation sought to deal with certain property to the limited extent of transferring her ownership of it to the control of the Receivers to carry into effect the Confiscation Order.

26. On 7 December 2017, the Receivers' appointment was varied to appoint the Receivers to take possession of, manage and deal with the property set out at schedule 1 to that order including the share in Casa Coloniches B. V. ("CCBV"), a Netherlands company ("the 2017 MRO"). Paragraphs three and four of the 2017 MRO required Dr Cochrane to - "...execute and deliver up stock transfer forms and/or take such further or other steps as [she] may be required to take by the Receivers so as to convey the [share in CCBV]...into the names of the Receivers or such other person(s) as the Receivers may direct"; and to: "...take all such reasonable and necessary steps as may be required by the Receivers to enable them to manage the [share in CCBV]..." 27. The 2017 MRO also contains a penal notice addressed to Dr Cochrane. Dr Cochrane, however, remains the registered shareholder of the sole share in CCBV. Further, she remains registered as the sole director of CCBV on the Dutch Trade Register, despite her appointment not being effective because, according to a letter of resignation dated 24 November 2016, she resigned as a director. As a result, there are no directors of CCBV, in breach of CCBV's articles of association.

28. Shortly after the Receivers' appointment, associates of Mr Smith delivered up certain books and records of CCBV to the Receivers. Thereafter, the Receivers made numerous requests of Dr Cochrane to assist in their management of CCBV including signing shareholder resolutions to appoint them as directors of CCBV, proxy documents to approve the filing of CCBV's financial statements and powers of attorney to enable the transfer of the share in CCBV to an entity controlled by the Receivers (without prejudice to any claims as to how she owned it - which were being determined in the proceedings brought by the SFO and Receivers in the Commercial Court of the High Court of Justice of England & Wales ("the Commercial Court Proceedings") - including her assertion that she did not hold it as nominee for Mr Smith).

29. On each occasion and despite the Receivers seeking to adjust the documentation in various ways to accommodate her requests including with the assistance of the Viscount (acting in Dr Cochrane's désastre proceedings), Dr Cochrane ignored or refused to comply with those requests.

30. In a judgment in the Commercial Court Proceedings dated 11 June 2021 ("the June 2021 judgment") Foxton J determined that Dr Cochrane held the shareholdings in a number of companies, including CCBV as a nominee for Mr Smith. He made consequential orders upon the resolution of the substantive claims which include at [16] that 100% of the equitable interest in the share of CCBV is held by Mr Smith. The orders in the June 2021 judgment follow the findings made by Foxton J in SFO & Anor v Litigation Capital Ltd & 46 Ors (In re Gerald Martin Smith) [2021] EWHC 1272 (Comm) at [606]).

31. The share in CCBV is therefore a realisable asset of Mr Smith for the purposes of the Confiscation Order. The Receivers therefore continue to wish to take actual possession of it, in accordance with the terms of their appointment. A subsidiary of CCBV holds immovable property, which the Receivers intend to realise. In order to achieve the realisation of that immovable property and use the proceeds of it in part satisfaction of the Confiscation Order, the Receivers must take actual possession of the share of CCBV.

32. In addition to Dr Cochrane's obligations under the 2017 MRO, she has given undertakings in the Commercial Court Proceedings to assist the Receivers, comply with their requests and to make the transfer of the CCBV share (as specified within the June 2021 judgment) to the Receivers and/or an entity controlled by them. If she does not, she is liable to be found in contempt of court. The nature of the variation sought 33. The Saisie as currently in force, prohibits Dr Cochrane from transferring the share in CCBV to anyone, including the Receivers. The 2008 ERO appoints the Receivers to take possession of and realise the property of Mr Smith, which includes the share in CCBV. The Receivers are currently appointed to take possession of, manage and deal with the share in CCBV on the terms of the 2017 MRO set out above. Accordingly, the Receivers are entitled and empowered to require Dr Cochrane to transfer the share in CCBV to them. They are currently prevented from doing so by the terms of the Saisie .

34. Therefore, a limited variation of the prohibition on Dr Cochrane dealing in the CCBV share can be made to fulfil the purpose of the 2017 MRO which includes the preservation and management of Mr Smith's assets so that such assets are available to pay the Confiscation Order. Specifically, to permit Dr Cochrane to transfer the share in CCBV to the Receivers (and/or any entity controlled or owned by them) but not to anyone else.

35. The amendment sought would therefore bring the Saisie in line with the English orders to which all the relevant parties (including Dr Cochrane) are already subject and bound by.

36. The variation would require Dr Cochrane in making the transfer (under the terms of the 2017 MRO and her own undertakings) to execute a power of attorney in favour of the Receivers' Dutch lawyers granting them the power to transfer the share to an entity controlled by the Receivers. If Dr Cochrane does not do so, she will be in contempt of the 2017 MRO and certain of the undertakings she provided to the English court, as recorded in the Order of Foxton J dated 4 February 2021 (" the LCL Settlement Order "). The law 37. On 21 April 2022 the Proceeds of Crime (Enforcement of Confiscation Orders) (Amendment) (Jersey) Regulations 2022 came into force (on the commencement of the Proceeds of Crime (Amendment No. 5) (Jersey) Law 2022). This brought into force the Proceeds of Crime (Enforcement of Confiscation and Instrumentalities Forfeiture Orders) (Jersey) Regulations 2008 . These 2008 Regulations shall still be defined as the Modified 1999 Law. Article 2 (1) defines " realisable property " as: "(1) In this Law, 'realisable property' means - (a) in relation to an external confiscation order in respect of specified property, the property that is specified in the order; (b) in any other case - (i) any property held by the defendant, (ii) any property held by a person to whom the defendant has directly or indirectly made a gift caught by this Law, and (iii) any property to which the

defendant is beneficially entitled." 38. Article 16 (4) of the Modified 1999 Law (which provision remains identical to the 1999 Law) states - "(4) Subject to paragraph (5), on the making of a saisie judiciaire - (a) all the realisable property held by the defendant in Jersey shall vest in the Viscount; (b) any specified person may be prohibited from dealing with any realisable property held by that person whether the property is described in the order or not; (c) any specified person may be prohibited from dealing with any realisable property transferred to the person after the making of the order, and the Viscount shall have the duty to take possession of and, in accordance with the Court's directions, to manage or otherwise deal with any such realisable property; and any specified person having possession of any realisable property may be required to give possession of it to the Viscount." 39. Article 16 (7) of the Modified 1999 Law (which provision remains identical to the 1999 Law) provides: "An application for the discharge or variation of a saisie judiciaire may be made to the Bailiff in chambers by any person affected by it and the Bailiff may rule upon the application or may, at the Bailiff's discretion, refer it to the Court for adjudication".

40. In Tantular [2020] JCA 234 the Court of Appeal held at paragraph 56 et seq of the judgment: "We accept the contention made by the Respondent (also accepted by the Royal Court - see paragraphs 41 and 42 of the judgment of Commissioner Clyde-Smith quoted at paragraph 37 above) that the obvious and natural meaning of Article 16(4)(a) is that the power conferred thereby can be exercised only in respect of property which is located in Jersey whereas the obvious and natural meaning of the power conferred by Article 16(4)(b) contains no such geographical limitation. In our judgment the applicability of Article 16(4)(b) to realisable property outside Jersey is clearly established, too, on a literal interpretation of the Modified Law, and, in particular, the definition of "property" in Article 1(1) as extending to property "whether situated in Jersey or elsewhere". Had Article 16(4)(b) and/or for that matter Article 16(c) been intended not to have extraterritorial effect, they could and no doubt would have been expressly limited, as was Article 16(4)(a), to property held in Jersey. Article 39, which was also relied upon by the Appellant in support of his general contention that the words of the Modified Law read as a whole supports his interpretation of Article 16(4)(b), takes the matter no further: the reference in that Article to "enforcing the order in Jersey" is to be read not as circumscribing the location of assets against which enforcement is possible, but simply as a reference to Jersey as the place where the decision to enforce any external confiscation order will be made under the Modified Law." ...

59. The purpose of a saisie under Article 16 is to permit interim orders to be made pending registration of an external confiscation order. By Article 16(4)(a), property held by the defendant in Jersey vests by operation of law in the Viscount, subject to the interests specified in Article 16(5). With vesting, subject to the directions of the court, come obligations to take possession of and manage that realisable property. Articles 16(4)(b) and (c), by contrast, enable prohibitions against specified persons on a discretionary basis. They offer the court the equivalent of a Mareva jurisdiction, which may take effect worldwide in the sense that a specified person can be prohibited from doing certain things outside the jurisdiction. Such prohibitions are unlikely to be issued against non-Jersey residents because of the difficulty of enforcement, but no territorial limitation by residence of specified persons (any more than by location of their assets) is expressed in the Modified Law.

60. The flexibility of the jurisdiction under Article 16(4)(b) and (c) appears from the various cases in which its exercise has been considered - compare, for example, Baroque Trust Company Ltd. and others v The Viscount [2004] JRC066, in which a saisie took effect over the whole of a trust and corporate structure and its underlying assets with the present case in which all the assets within the trust structure were initially the subject of a saisie but subsequently, upon the Appellant's application to the Royal Court, some of the assets held in the trust structure were released. It allows the Court, pending registration of an external confiscation order, to make interim orders the effect of which is to ensure that the assets of a criminal or suspected criminal are retained pending a resolution of the issues relating to confiscation; such orders, without doubt, provide significant assistance in helping to protect Jersey's reputation in financial matters.

61. That flexibility is particularly evident, and potentially advantageous, where tainted gifts are concerned. A tracing exercise is not required - applying the definition in Article 2(1)(a)(ii), any property held by the donee may be kept available to satisfy the confiscation order. The extraterritorial nature of the jurisdiction may also be of practical value. Were it territorially limited as the Appellant claims, a tainted gift to an otherwise impecunious defendant's sister living in Jersey could escape prohibition by the simple device of placing it in her Guernsey or UK bank account. The Mareva-type jurisdiction may be further supported by the Court's inherent powers in relation to its orders, for example to order the disclosure and provenance of assets and, if the specified person does not bring them back voluntarily, to order their repatriation to Jersey for safekeeping - see, by analogy, the judgment of the English Court of Appeal in DPP v Scarlett [1999] 1 WLR 515 at 521G-523B. Once such assets are physically in Jersey, Article 17 empowers the Court to authorise the Viscount to realise such property; the Court has assets within its jurisdiction and can make orders "in such manner as it may direct" so as to enable realisation to take place.

62. We do not doubt that there will cases in which an order extending to realisable property abroad could have resource implications and may be complex or difficult to enforce. It is important, however, to emphasise that such difficulties do not arise by automatic operation of the Modified Law. The Court has a discretion in all cases. Specified persons who are subject to a prohibition under Article 16(4)(b) or (c) may, but do not have to be, subject to an order to transfer possession of their property to the Viscount - that is the import of the final clause of Article 16(4). If problematic consequences are envisaged, such an order may be refused or (as was the case in Kaplan, where there was a risk of conflicting orders between the Swiss and Jersey courts), discharged. The Viscount's duty to take possession of realisable property situated outside the Island, like her duty to manage or otherwise deal with such property, arises only in circumstances where the Court has directed a specified person to give possession of it to her. One would not normally expect the Court to make such an order without hearing from the Viscount, or being satisfied by the Attorney General that the Viscount has no objection to such an order being made. This links to the provisions in Article 17 of the Modified Law that realisation of property is only possible where there has been a saisie judiciaire and

property has either vested in the Viscount or been transferred to her possession pursuant to Article 16." 41. This statement of the Law remains good and is unaffected by the judgment of the Judicial Committee of the Privy Council in the appeals of (and cross appeals in) Robert Tantular, Tan Chi Fang and 3 others v His Majesty's Attorney General [2023] UKPC 21 . It appears from the judgment in Tantular that although property outside Jersey did not fall under 16(4)(a) and could not therefore immediately vest in the Viscount, it could fall within 16 (4) (b) or (c), such that any person could be prohibited from dealing with it. In this way, assets outside Jersey but, for example, forming part of a Jersey-administered Trust could fall within the scope of a Saisie and falls within the jurisdiction of the Court. Dr Cochrane, as a Jersey resident, plainly does. It is also plain, that upon the registration of the ECO and the terms of the Saisie , the share in CCBV is part of Mr Smith's realisable property for the purposes of satisfying the Confiscation Order.

42. It follows, in my view, that the Court does have the power to prevent Dr Cochrane (or any person) from dealing with the share in CCBV and by that token transferring that share to any other person. The converse power is then available to the Court upon this application namely to permit a transfer of title to that share to the Receivers.

43. In circumstances where Dr Cochrane has given enforceable undertakings in the Commercial Court Proceedings, which anticipate the transfer of her share in CCBV in a particular manner with which she agrees and which she has been directed to do by the terms of 2017 MRO and has undertaken to do as recorded the LCL Settlement Order, it follows that a variation which permits her dealing with that property can properly include similar directions as to how, if the transfer is executed by Dr Cochrane, it may be managed. These further directions simply have the effect of specifying an orderly means by which the transfer may be achieved and in my view do not exceed the proper ambit of a Saisie . Conclusion 44. Mr Smith did not appear before us to argue in connection with this application although he had indicated that he resisted it at a previous hearing before the Court on 22 August 2024 when directions were given. On that occasion Mr Smith also applied for a stay of the application, which was refused, reasons being given in an ex tempore judgment. Since that date, at Southwark Crown Court, Mr Smith was sentenced by His Honour Judge Cole to 18 months' imprisonment for fraud. On 6 December 2024, Henshaw J ordered the committal of Mr Smith to gaol for contempt of Court for a period of 13 months', to run consecutively to the prison sentence he was currently serving for fraud. Therefore, by the time of the hearing Mr Smith was in custody in England.

45. A number of attempts were made to ascertain whether Mr Smith wished to attend the hearing via video link and what his position was. The Court was provided with the records from the prison authorities as to the outcome of those enquiries. In short, Mr Smith indicated that he no longer intended to oppose the application and remained neutral. However, he wished to make some observations and the Attorney General then sought permission from the Court to grant a video link for that purpose. However, before the matter came back to Court it was recorded by the prison authorities that Mr Smith's position was reserved and that he was not willing to attend, although he would do so in person had he the necessary papers.

46. The Court received additional written submissions from the Attorney General in relation to whether the Court should proceed in Mr Smith's absence. Having considered those submissions and in light of the authorities cited therein, the Court was of the view that it would proceed in the absence of Mr Smith.

47. Dr Cochrane did appear although was unrepresented. She remained to listen to the submissions and the determination of the Court but she informed the Court that she had been notified that if she were to resist in any way she would be in contempt of court and therefore she made no submissions to the Court. Counsel for the Attorney General, however, confirmed to this Court that if need be, and if there were concerns as to the way assets were administered, it would be open both to Mr Smith or Dr Cochrane to apply to the Commercial Court in England and Wales.

48. In essence, it is put before me that the shares in question, CCBV, comprise realisable property and are in the terms of both the Saisie and the Receivers' appointment. They are held by Dr Cochrane as Mr Smith's nominee and are realisable property under the Saisie . Accordingly, all that the application to vary is seeking to achieve is the transfer of those assets into the control of the Receivers. No order was sought against Dr Cochrane (and indeed at the current time she is en désastre ) save that within the terms of the draft order, upon being permitted to transfer the share in CCBV, that she do so in a particular manner as explained in paragraph 43, above and immediately below.

49. For the reasons set out above, the Court granted the application of the Attorney General in the terms of a draft order put before it which is attached to this judgment as a schedule for ease of reference. In essence, with consequential orders made in support, it permits Dr Cochrane to deal with the shares registered in her name that form the subject of the application to the extent only of the variation and expressly to transfer title to the Receivers.

50. We record that this order has been made without opposition and we are extremely grateful to counsel for the Attorney General for the detailed skeleton argument and submissions upon which the Court has relied and, to a large extent, adopted in setting out its reasoning above. Authorities Proceeds of Crime (Jersey) Law 1999. Proceeds of Crime (Designated Countries and Territories) (Jersey) Regulations 1999. Proceeds of Crime (Enforcement of Confiscation and Instrumentalities Forfeiture Orders) (Jersey) Regulations 2008. Proceeds of Crime (Enforcement of Confiscation Orders) (Jersey) Regulations 2008. Bankruptcy (Désastre) (Jersey) Law, 1990. In the matter of the Désastre of Dr Gail Cochrane [2024] JRC 043 . ORB a.r.l & Ors v Ruhan & Ors [2016] EWHC 850 (Comm) . SFO & Anor v Litigation Capital Ltd & 46 Ors (In re Gerald Martin Smith) [2021] EWHC 1272 (Comm) . Proceeds of Crime (Enforcement of Confiscation Orders) (Amendment) (Jersey) Regulations 2022. Robert Tantular v AG [2020] JCA 234 . Robert Tantular, Tan Chi Fang and 3 others v His Majesty's Attorney General [2023] UKPC 21 . Page Last Updated: 16 Oct 2025 BAILII: Copyright Policy | Disclaimers | Privacy Policy | Feedback | Donate to BAILII