EWCA Crim 1036
The principle in R. v Briggs-Price (Robert William)  UKHL 19,  1 A.C. 1026 only arose in the most limited circumstances, namely where the Crown sought to prove the criminal offence of money laundering with a view to establishing benefit. It did not arise where the Crown sought to rely on criminal offending other than a conviction to establish the existence and quantum of a defendant's benefit from criminal conduct. The burden of proof on the Crown in such circumstances remained the civil standard, not the criminal standard.
CA (Crim Div) (Davis LJ, Treacy J, Judge Peter Collier QC (Recorder of Leeds))