On 22 January, an article from Bright Line Law said that circumvention offences establish criminal liability for breaches of financial sanctions.  The potential engagement of the circumvention offences invites a review into whether the offences interact with the Proceeds of Crime Act 2002.   Circumvention offences are contained within each financial sanctions’ regime legislation. The article says that such offences couldalso contravene POCA, saying that POCA 2002 was drafted to stop the collection and retention of funds derived from criminal conduct.  Criminal conduct is an activity which would amount to an offence in England and Wales, and if funds are obtained from a circumvention offence, they will represent the proceeds of crime and engage parts of POCA 2002.  It also says that courts could order confiscation, but only if the court is satisfied that the funds represent the benefit of a defendant’s criminal conduct.

I would be grateful for any modest contribution for my time and ongoing costs of computer, relocation, and (still ongoing) removal costs, I have a page, where contributions start as low as $3, at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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