The test to be applied when seeking restraint orders under the Proceeds of Crime Act 2002 s.40(2)(a), when read in conjunction with the Proceeds of Crime Act 2002 (Commencement No. 5, Transitional Provisions, Savings and Amendment) Order 2003, was whether an investigation had begun into an offence that had taken place after March 24, 2003.

[2005] EWCA Crim 3271