Given that the Criminal Justice Act 1988 was concerned with forcing a defendant to surrender the benefit he had obtained from his criminal activity, so long as the benefit he had obtained was correctly calculated it could not be disproportionate for him to be made accountable for it. The amount of the benefit he obtained was not affected by the amount that might also have been obtained by others to whom he transferred any part of the benefit.

[2006] EWCA Crim 16

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