In granting confiscation orders against the appellants, following their conviction for conspiracy to cheat, the trial judge was entitled to hold that property held by various companies, which were jointly controlled by various of the appellants, was the joint property of the appellants for the purposes of the Criminal Justice Act 1988 s.71(4). However, they were entitled to rely upon an indication from the trial judge, given in chambers, that he would only look to their identifiable assets in making the confiscation orders.

[2005] EWCA Crim 97