EWCA Crim 2736
Applying the principles to be considered when imposing a default term of imprisonment for a confiscation order as restated in R. v Castillo (German)  EWCA Crim 3173,  2 Cr. App. R. (S.) 36, a default sentence of eight years' imprisonment for failure to pay a confiscation order in excess of £1 million was manifestly excessive. It was appropriate to reduce the default term to 6 years.
CA (Crim Div) (McCombe LJ, Eder J, Globe J)