In 2018, the City of London Police (CoLP) obtained account freezing orders (AFOs) over our clients’ business and personal accounts.

Our clients, and their UK-incorporated company, had unwittingly become embroiled in a large-scale money laundering investigation, involving a complex web of UK bank accounts held by overseas nationals.

From early in our instruction, we asserted the statutory defence under section 308 of the Proceeds of Crime Act on our clients’ behalf (receipt in good faith, for value and without notice).

In 2019, our clients sadly found themselves caught up in a further money laundering investigation, this time conducted by the National Crime Agency (NCA). Our clients were arrested, their home searched, and property seized.

Shortly prior to the expiration of the AFOs in September 2020, we were notified that the CoLP had applied for civil forfeiture of the majority of the frozen funds. Together with counsel, Kennedy Talbot QC of 33 Chancery Lane, we advised our clients on resisting the application. Following the service by us of evidence of fact and expert evidence, the CoLP agreed to withdraw its application for forfeiture.

On the same day that the CoLP application was withdrawn, HM Revenue & Customs (HMRC) applied for and was granted a further AFO over the same funds in our clients’ company account. Only eight days later, following the submission of written representations by us, HMRC applied for the discharge of the further AFO.

More than £500,000 has since been returned to our clients.

In July 2022, we were informed that the NCA investigation had been concluded, and no further action would be taken against our clients. Their seized property has now been returned.