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Civil Recovery Orders: Law, Policy and Practice

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Book cover Negotiated Justice and Corporate Crime

Part of the book series: Crime Prevention and Security Management ((CPSM))

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Abstract

This chapter explores the development of civil recovery as an enforcement tool in the context of corporate crime. It explores the preference for ‘civil settlement’, with the consequence that corporate wrongdoers can avoid criminal prosecution. A number of concerns are explored in this regard. This chapter also examines the divergent approaches of the Serious Fraud Office and the Scottish Civil Recovery Unit, namely that as the rest of the UK moves away from CROs, such powers remain an important cog in the Scottish enforcement response to corporate crime.

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Notes

  1. 1.

    The civil recovery provisions came into force on February 24, 2003: SI 2003/120 The Proceeds of Crime Act 2002 (Commencement No. 4, Transitional Provisions and Savings) Order 2003.

  2. 2.

    For consideration of arguments in favour of civil recovery, see Anthony Kennedy, ‘Justifying the Civil Recovery of Criminal Proceeds’, Journal of Financial Crime (2004), 12(1): 8. See also Colin Nicholls, Timothy Daniel, Alan Bacarese, and John Hatchard, Corruption and Misuse of Public Office (2nd ed, Oxford University Press, 2011), p. 255 et seq.

  3. 3.

    See, generally, Michelle Gallant, Money Laundering and the Proceeds of Crime: Economic Crime and Civil Remedies (Edward Elgar, 2005). See also Liz Campbell, ‘The Recovery of “Criminal” Assets in New Zealand, Ireland and England: Fighting Organised and Serious Crime in the “Civil” Realm’, Victoria University Wellington Law Review (2010), 41: 15; John Lea, ‘Hitting Criminals Where It Hurts: Organised Crime and the Erosion of Due Process’, Cambrian Law Review (2004), 35: 81.

  4. 4.

    Jennifer Hendry and Colin King, ‘How Far is Too Far? Theorising Non-Conviction-Based Asset Forfeiture’, International Journal of Law in Context (2015), 11(4): 398, 407.

  5. 5.

    OECD, Implementing the OECD Anti-Bribery Convention. Phase 4 Report: United Kingdom (OECD, 2017), p. 59.

  6. 6.

    Peter Alldridge, ‘Bribery and the Changing Pattern of Criminal Prosecution’, in Jeremy Horder and Peter Alldridge (eds), Modern Bribery Law: Comparative Perspectives (Cambridge University Press, 2013), p. 247.

  7. 7.

    See David Beetham, The Legitimation of Power (2nd ed, Palgrave Macmillan, 2013). See also Ota Weinberger, ‘Legal Validity, Acceptance of Law, Legitimacy: Some Critical Comments and Constructive Proposals’, Ratio Juris (1999), 12(4): 336.

  8. 8.

    Jennifer Hendry and Colin King, ‘Expediency, Legitimacy, and the Rule of Law : A Systems Perspective on Civil/Criminal Procedural Hybrids’, Criminal Law and Philosophy (2017), 11(4): 733.

  9. 9.

    All eleven CROs involve allegations of bribery and/or corruption, so our focus is primarily on such wrongdoing.

  10. 10.

    SFO, Approach of the Serious Fraud Office to Dealing with Overseas Corruption (July 2009). The explicit emphasis on settling such self-report cases ‘civilly wherever possible’ was removed in 2012. See Debevoise and Plimpton LLP, Client Update: Serious Fraud Offices Issues New Policies on Self-Reporting, Facilitation Payments and Business Expenditures (October 12, 2012).

  11. 11.

    Peter Alldridge, ‘Civil Recovery in England and Wales: An Appraisal’, in Colin King, Clive Walker, and Jimmy Gurulé (eds), The Handbook of Criminal and Terrorism Financing Law (Palgrave, 2018), p. 516.

  12. 12.

    See OECD, Phase 3 Report on Implementing the OECD Anti-Bribery Convention in the United Kingdom (March 2012), p. 33.

  13. 13.

    R v Innospec Limited, Sentencing Remarks, Crown Court at Southwark, March 26, 2010, Thomas LJ, para. 38.

  14. 14.

    Such as an inadequate legal framework and difficulties in obtaining evidence overseas.

  15. 15.

    Such as political interference by the executive (the BAE Systems case was the epitome of this). These issues are developed further in Chapter 6.

  16. 16.

    Nicholas Lord, ‘Establishing Enforcement Legitimacy in the Pursuit of Rule-Breaking “Global Elites”: The Case of Transnational Corporate Bribery’, Theoretical Criminology (2016), 20(3): 376, 398. See also David Leigh, ‘The Fall Guy’, The Guardian (April 18, 2008).

  17. 17.

    See SFO, Approach of the Serious Fraud Office to Dealing with Overseas Corruption (July 2009).

  18. 18.

    Fraudwatch, Alderman Forced to Leave OECD Advisory Group, May 7, 2015, available at: https://fraudwatchonline.com/index.php/news/briberyandcorruption/3480-alderman-forced-to-leave-oecd-advisory-group (last accessed January 19, 2018).

  19. 19.

    See Tim Harvey, ‘Man on a Mission’, Fraud Magazine, November/December 2013.

  20. 20.

    DPAs are discussed in Chapters 4 and 5.

  21. 21.

    Provision for ‘Consent Orders’ is contained in POCA, s.276(1).

  22. 22.

    See the Stolen Asset Recovery Initiative (StAR) Corruption Database ‘Balfour Beatty Plc’, available at: http://star.worldbank.org/corruption-cases/node/19833 (last accessed October 20, 2017).

  23. 23.

    See Transparency International (UK), Deterring and Punishing Corporate Bribery : An Evaluation of UK Corporate Plea Agreements and Civil Recovery in Overseas Bribery Cases (Transparency International, 2012), p. 65.

  24. 24.

    See the Stolen Asset Recovery Initiative (StAR) Corruption Database ‘AMEC plc’, available at: http://star.worldbank.org/corruption-cases/node/19815 (last accessed October 20, 2017). It has been suggested that the construction project in question was the Incheon Bridge in Korea: Simon Bowers, Amec and Serious Fraud Office settle $9 million “irregular receipts” case, The Guardian (October 26, 2009).

  25. 25.

    Cited in the Stolen Asset Recovery Initiative (StAR) Corruption Database ‘Bonny Island Liquefied Natural Gas Bribe Scheme (TSKJ Consortium)/KBR—M.W. Kellogg Ltd’, available at: https://star.worldbank.org/corruption-cases/node/20226 (last accessed October 20, 2017).

  26. 26.

    Cited in the Stolen Asset Recovery Initiative (StAR) Corruption Database ‘Johnson & Johnson/DePuy International Ltd (UK subsidiary)’, available at: http://star.worldbank.org/corruption-cases/node/20234 (last accessed October 20, 2017).

  27. 27.

    Transparency International (UK), Deterring and Punishing Corporate Bribery : An Evaluation of UK Corporate Plea Agreements and Civil Recovery in Overseas Bribery Cases (Transparency International, 2012), p. 65.

  28. 28.

    In a negotiated resolution, in April 2010, MacMillan Limited was debarred from World Bank contracts for a period of six years.

  29. 29.

    Namely Rwanda, Uganda, and Zambia.

  30. 30.

    Cited in the Stolen Asset Recovery Initiative (StAR) Corruption Database ‘MacMillan Publishers Limited’, available at: http://star.worldbank.org/corruption-cases/node/20100 (last accessed October 20, 2017).

  31. 31.

    See the Stolen Asset Recovery Initiative (StAR) Corruption Database ‘Mabey Engineering (Holdings) Ltd’, available at: http://star.worldbank.org/corruption-cases/node/20233 (last accessed October 20, 2017).

  32. 32.

    J. Pickworth and C. Lee, Dechert On Point—Special Alert (January 2012), available at: https://www.dechert.com/files/Publication/1d9cdaa5-638d-4c9b-b0f5-865899aa38b8/Presentation/PublicationAttachment/d203cec1-b012-4e93-90fb-8a552c9e58af/White_Collar_SA_01-12_SFO_Recovers.pdf (last accessed October 20, 2017).

  33. 33.

    See, for example, C. Binham and K. Burgess, ‘Investors alarmed by SFO warning’, Financial Times, January 12, 2012.

  34. 34.

    Cited in FCPA Compliance Report, The SFO Speaks in the Mabey & Johnson Case: Private Equity – Are You Listening? available at: http://fcpacompliancereport.com/2012/01/the-sfo-speaks-in-the-mabey-johnson-case-private-equity-are-you-listening/ (last accessed July 28, 2017).

  35. 35.

    See Transparency International (UK), Deterring and Punishing Corporate Bribery : An Evaluation of UK Corporate Plea Agreements and Civil Recovery in Overseas Bribery Cases (Transparency International, 2012), p. 65.

  36. 36.

    Colin Nicholls, Timothy Daniel, Alan Bacarese, and John Hatchard, Corruption and Misuse of Public Office (2nd ed, Oxford University Press, 2011), p. 218.

  37. 37.

    The SFO has pursued CROs against individuals, related to financial wrongdoing involving corporates, such as in the case of Griffiths Energy International Inc. For background to that case, see SFO v Saleh [2015] EWHC 2119 (QB).

  38. 38.

    SFO Press Release, Oxford Publishing Ltd to Pay Almost £1.9 Million as Settlement After Admitting Unlawful Conduct in Its East African Operations (July 3, 2012).

  39. 39.

    OUP made a separate self-referral to the World Bank, as two of the tenders in question were funded by the World Bank. As part of a Negotiated Resolution Agreement between OUP and the World Bank, OUPEA and OUPT were debarred for three years while OUP received a conditional non-debarment.

  40. 40.

    SFO Press Release, Oxford Publishing Ltd to Pay Almost £1.9 Million as Settlement After Admitting Unlawful Conduct in Its East African Operations (July 3, 2012).

  41. 41.

    According to the press release, ‘This was a reflection of the seriousness with which OUP views the course of events that were subject to the investigation and a wish to acknowledge that the conduct of OUPEA and OUPT fell short of that expected within its wider organisation’. Ibid.

  42. 42.

    Ibid.

  43. 43.

    Ibid.

  44. 44.

    Donald R. Cressey, ‘Negotiated Justice’, Criminology (1968), 5(4): 5, 9.

  45. 45.

    Though it is recognised that the SFO noted that the Code for Crown Prosecutors was not met in this instance.

  46. 46.

    See, for example, Barry Vitou and Richard Kovalevsky, ‘When It Comes to Corporate Crime—in the Whitehall Corridors of Power: The Fight Is on’, available at: http://thebriberyact.com/2011/02/21/when-it-comes-to-corporate-crime-in-the-whitehall-corridors-of-power-the-fight-is-on/ (last accessed January 18, 2018).

  47. 47.

    OECD, Phase 3 Report on Implementing the OECD Anti-Bribery Convention in the United Kingdom (March 2012).

  48. 48.

    HM Crown Prosecution Service Inspectorate (HMCPSI), Report to the Attorney General on the Inspection of the Serious Fraud Office (November 2012).

  49. 49.

    Transparency International (UK), Deterring and Punishing Corporate Bribery : An Evaluation of UK Corporate Plea Agreements and Civil Recovery in Overseas Bribery Cases (Transparency International, 2012).

  50. 50.

    COPFS, Guidance on the Approach of the Crown Office and Procurator Fiscal Service to Reporting by Businesses of Bribery Offences (June 2017), para. 1.

  51. 51.

    There is no indication what factors influence whether the self-reporting initiative will be continued or otherwise during this annual review.

  52. 52.

    Civil Recovery Unit, Civil Recovery Unit Annual Report 2012/13 (Scottish Government), p. 9.

  53. 53.

    John Hull and Dan Smith, The Future of Civil Settlements in Criminal Matters (Latham & Watkins, In Practice, April 2013), available at: https://www.lw.com/thoughtLeadership/The-Future-of-Civil-Settlements-in-Criminal-Matters (last accessed November 3, 2017). See also Gordon Kaiser, ‘Corruption in the Energy Sector: Criminal Fines, Civil Judgments and Lost Arbitrations’, Energy Law Journal (2013), 34(1): 193, 237.

  54. 54.

    Note, the company did not assert that its anti-bribery and corruption policies were adequate—which would have provided a complete defence.

  55. 55.

    See Jody Harrison, Firm Pays Fine After Reporting Itself to Crown Office, The Herald (September 25, 2015); Laura Forde, Failing to Prevent Bribery — Prevention Is Better than Cure, DLA Piper Regulatory Update (October 13, 2015).

  56. 56.

    While CROs went against Green’s hard-line prosecutorial stance, it must be recognised that he re-iterated on numerous occasions the importance of self-reporting (e.g. David Green, Speech at the Inaugural Fraud Lawyers Association, March 26, 2013). Indeed, self-reporting remains an important consideration for the SFO under the new DPA regime implemented in 2013 (see Chapter 4).

  57. 57.

    Johanna Walsh, Lessons Learned from the First Resolution Under s7 of the Bribery Act, Kingsley Napley Criminal Law Blog (October 6, 2015), available at: https://www.kingsleynapley.co.uk/insights/blogs/criminal-law-blog/lessons-learned-from-the-first-resolution-under-s7-of-the-bribery-act (last accessed November 3, 2017).

  58. 58.

    See Debevoise and Plimpton LLP, ‘UK “Corporate Offence”—Scottish Company Enters First Settlement Expressly Relating to Section 7 of the Bribery Act’, FCPA Update (October 2015, vol. 7, no. 3), p. 15.

  59. 59.

    It is also worth noting that, on the basis of his knowledge of, and involvement in, a bribery arrangement a court order was granted for the purchase of shares held by a director of the company. That director only received ‘par value’ for his shareholding—which was approximately £18 million less than the actual value of his shareholding: In the petition of Nigel Gray and ors, for Orders pursuant to sections 994 and 996 of the Companies Act 2006 in respect of Braid Group (Holdings) Ltd [2015] CSOH 146, para. 161. This decision was upheld on appeal: In the Reclaiming Motion of Nigel Anthony Harden Gray and ors, for Orders pursuant to sections 994 and 996 of the Companies Act 2006 in respect of Braid Group (Holdings) Ltd [2016] CSIH 68. See also In the cause of Nigel Anthony Harden Gray against Braid Logistics (UK) Ltd [2017] CSOH 44.

  60. 60.

    The CRU press release is reproduced on ‘thebriberyact.com’ website: Barry Vitou and Richard Kovalevsky, ‘Civil Settlement for Scottish Company which self-reported violations of section 1 & section 7 of the Bribery Act highlights difference of approach North of the Border’, available at: http://thebriberyact.com/2016/04/17/civil-settlement-for-scottish-company-which-self-reported-violations-of-section-1-section-7-of-the-bribery-act-highlights-difference-of-approach-north-of-the-border/ (last accessed November 6, 2017).

  61. 61.

    OECD, Implementing the OECD Anti-Bribery Convention: Phase 4 Report: United Kingdom (OECD, 2017), para. 152.

  62. 62.

    The Scottish Guidance envisages a speedy process, with an initial evaluation from SOCU expected within 8 weeks of the self-report: see COPFS, Guidance on the Approach of the Crown Office and Procurator Fiscal Service to Reporting by Businesses of Bribery Offences (June 2017), para. 13.

  63. 63.

    Ibid., para. 4.

  64. 64.

    See Ibid., para. 5. In practice, however, there are practical difficulties. For example, in 2014 an MOU was signed between various law enforcement agencies (namely COLP, COPFS, CPS, FCA, MDP, NCA, and SFO) establishing new rules for assigning foreign bribery cases. A separate MOU was also signed between the COPFS and the SFO setting out further rules for co-ordination and co-operation between those agencies. However, during the 2017 OECD Phase Four evaluation, ‘Representatives of the Scottish police and prosecuting authorities were unfortunately not aware of the existence of the 2014 MOUs and how they affect the attribution of foreign bribery cases between the SFO and Scottish authorities’. OECD, Implementing the OECD Anti-Bribery Convention: Phase 4 Report: United Kingdom (OECD, 2017), para. 75.

  65. 65.

    COPFS, Guidance on the Approach of the Crown Office and Procurator Fiscal Service to Reporting by Businesses of Bribery Offences (June 2017), para. 7.

  66. 66.

    Ibid., para. 8.

  67. 67.

    Ibid., para. 9.

  68. 68.

    Ibid.

  69. 69.

    Ibid., para. 10.

  70. 70.

    Ibid. In such cases, ‘it is envisaged that the business will continue to cooperate with law enforcement. … The business will be able to rely on their self-reporting and co-operation with the Crown and law enforcement as significant mitigating factors to be taken into account by the Court’ (ibid., para. 10).

  71. 71.

    The CRU may dispense with the requirement to instruct a third party forensic accountancy firm, for example where the business has submitted a forensic accountancy report as part of the self-report. This will be determined on a case-by-case basis. Ibid., para. 22.

  72. 72.

    Ibid., para. 15. The Guidance later states: ‘The costs incurred by the business in respect of the forensic accountants may be taken into account when determining the appropriate level of any extra-judicial settlement but there should be no expectation by the business that these costs will be taken into account in every case’ (ibid., para. 21).

  73. 73.

    Ibid., para. 18.

  74. 74.

    Ibid., para. 19.

  75. 75.

    Ibid.

  76. 76.

    Ibid., para. 20.

  77. 77.

    For further discussion of Innospec and ‘global settlements’, see Polly Sprenger, Deferred Prosecution Agreements: The Law and Practice of Negotiated Corporate Criminal Penalties (Sweet and Maxwell, 2015), pp. 501–506. Sprenger notes that ‘the term global is something of a misnomer’; indeed, global settlements have been used even where only one jurisdiction is affected (ibid., p. 499).

  78. 78.

    R v Innospec Limited, Sentencing Remarks, Crown Court at Southwark, March 26, 2010, Thomas LJ, para. 4.

  79. 79.

    Including the Department of Justice (DOJ), the Securities and Exchange Commission (SEC), and the Office of Foreign Asset Control (OFAC).

  80. 80.

    Although the Iraq corruption could have been prosecuted in the UK, the SFO had adopted the view that the most logical approach was to split the criminal liability of Innospec Inc and Innospec Ltd in this manner.

  81. 81.

    ‘It was accepted that it was for the court to determine the appropriate sentence, but the parties submitted that the approach upon which they were agreed should commend itself to the court as it was compatible with the approach being adopted in the US’. R v Innospec Limited, Sentencing Remarks, Crown Court at Southwark, March 26, 2010, Thomas LJ, para. 17.

  82. 82.

    These would equate to £4.4 million (confiscation order) and £3.9 million (CRO) using the exchange rate on the day in question.

  83. 83.

    See Innospec , paras. 18–20.

  84. 84.

    See Innospec , paras. 23–28.

  85. 85.

    Innospec , para. 26.

  86. 86.

    Innospec , para. 27.

  87. 87.

    Innospec , para. 27.

  88. 88.

    Innospec , para. 28.

  89. 89.

    Innospec , para. 30.

  90. 90.

    Innospec , para. 31.

  91. 91.

    Innospec , para. 31.

  92. 92.

    Innospec , para. 32.

  93. 93.

    Ibid.

  94. 94.

    Innospec , para. 34.

  95. 95.

    Innospec , para. 36.

  96. 96.

    See Innospec , para. 37.

  97. 97.

    As Thomas LJ stated: ‘it is difficult to see why no compensation was being paid in respect of the corruption in Indonesia which was charged and punished in the UK, whilst paying compensation in respect of the corruption in Iraq which was charged and punished in the US’. Innospec , para. 37.

  98. 98.

    Innospec , para. 38.

  99. 99.

    Innospec , para. 40. This view did take account of the fact that (1) the company would be entitled to credit for its early guilty plea and its cooperation with the investigation and (2) the management had changed and that an enhanced compliance programme was put in place.

  100. 100.

    Innospec , para. 42.

  101. 101.

    Innospec , para. 41.

  102. 102.

    Innospec , para. 47.

  103. 103.

    Innospec , para. 49.

  104. 104.

    Innospec , para. 42.

  105. 105.

    Ibid. The court also referred to the decision in R v Whittle & Others [2008] EWCA Crim 2560.

  106. 106.

    Innospec , para. 42.

  107. 107.

    Innospec , para. 43.

  108. 108.

    Innospec , para. 43.

  109. 109.

    Innospec , para. 45.

  110. 110.

    The other 50% goes to the Home Office.

  111. 111.

    Home Office, Asset Recovery Statistical Bulletin 2011/12–2016/17. Statistical Bulletin 15/17 (September 2017), p. 9.

  112. 112.

    See, for example, Dick M. Carpenter, Lisa Knepper, Angela C. Erickson, and Jennifer McDonald, Policing for Profit: The Abuse of Civil Asset Forfeiture (2nd ed, Institute for Justice, 2015); Eric Blumenson and Eva Nilsen, ‘Policing for Profit: The Drug War’s Hidden Economic Agenda’, University of Chicago Law Review (1998), 65(1): 35–114. Further concerns have been expressed as to ‘potentially counter-productive aspects of the operation of ARIS’: see HM Crown Prosecution Service Inspectorate, HM Inspectorate of Court Administration, and HM Inspectorate of Constabulary, Joint Thematic Review of Asset Recovery: Restraint and Confiscation Casework (Criminal Justice Joint Inspection, 2010), para. 6.1 et seq.

  113. 113.

    See Innospec , para. 36.

  114. 114.

    Innospec , para. 47.

  115. 115.

    Martin Collins and Colin King, ‘The Disruption of Crime in Scotland Through Non-conviction Based Asset Forfeiture’, Journal of Money Laundering Control (2003), 16(4): 379, 383.

  116. 116.

    CashBack for Communities, Who We Are, available at: http://cashbackforcommunities.org/ (last accessed November 16, 2017). For further discussion of the use of realised assets under proceeds of crime legislation, see Barbara Vettori, ‘The Disposal of Confiscated Assets in the EU Member States: What Works, What Does Not Work and What is Promising’, in Colin King, Clive Walker, and Jimmy Gurulé (eds), The Handbook of Criminal and Terrorism Financing Law (Palgrave, 2018).

  117. 117.

    CashBack for Communities, available at: http://cashbackforcommunities.org/ (last accessed November 16, 2017). For examples of such projects, see CashBack for Communities, Annual Report 2015–2016 (Scottish Government, 2016). See also National Evaluation of the CashBack for Communities Programme (April 2012–March 2014) Final Report (ODS Consulting, 2014).

  118. 118.

    Crown Office and Procurator Fiscal Services, Press Release—Abbot Group Limited to Pay £5.6 million after Corruption Report (November 23, 2012).

  119. 119.

    See Donald R. Cressey, ‘Negotiated Justice’, Criminology (1968), 5(4): 5, 9.

  120. 120.

    Serious Crime Act 2007 (Commencement No. 2 and Transitional and Transitory Provisions and Savings) Order 2008. Factors that might influence the use of non-conviction based powers are set out in Attorney General, Guidance for prosecutors and investigators on their asset recovery powers under Section 2A of the Proceeds of Crime Act 2002 (November 29, 2012).

  121. 121.

    OECD, Phase 3 Report on Implementing the OECD Anti-Bribery Convention in the United Kingdom (March 2012), p. 22.

  122. 122.

    Ibid., p. 23. See also Transparency International (UK), Deterring and Punishing Corporate Bribery : An Evaluation of UK Corporate Plea Agreements and Civil Recovery in Overseas Bribery Cases (Transparency International, 2012), p. 64.

  123. 123.

    HM Crown Prosecution Service Inspectorate (HMCPSI), Report to the Attorney General on the inspection of the Serious Fraud Office (November 2012), p. 3.

  124. 124.

    Ibid., p. 35.

  125. 125.

    Ibid.

  126. 126.

    Transparency International (UK), Deterring and Punishing Corporate Bribery : An Evaluation of UK Corporate Plea Agreements and Civil Recovery in Overseas Bribery Cases (Transparency International, 2012), pp. 63–64.

  127. 127.

    HM Crown Prosecution Service Inspectorate (HMCPSI), Report to the Attorney General on the Inspection of the Serious Fraud Office (November 2012), p. 35.

  128. 128.

    Ibid., p. 36.

  129. 129.

    SFO Press Release, Oxford Publishing Ltd to Pay Almost £1.9 Million as Settlement After Admitting Unlawful Conduct in Its East African Operations (July 3, 2012).

  130. 130.

    OECD, Implementing the OECD Anti-Bribery Convention: Phase 4 Report: United Kingdom (OECD, 2017), para. 156.

  131. 131.

    The cases specifically cited in support were: Innospec; Smith & Ouzman; Standard Bank; XYZ Ltd; Oxford Publishing Ltd; Sweett Group; and Chapman (Securency).

  132. 132.

    HM Crown Prosecution Service Inspectorate (HMCPSI), Follow-up Inspection of the Serious Fraud Office (November 2014), p. 31.

  133. 133.

    OECD, Implementing the OECD Anti-Bribery Convention: Phase 4 Report: United Kingdom (OECD, 2017), para. 157.

  134. 134.

    Ibid., p. 60.

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  1. School of Law, University of Sussex, Falmer, Brighton, UK

    Colin King

  2. School of Law, University of Manchester, Manchester, UK

    Nicholas Lord

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King, C., Lord, N. (2018). Civil Recovery Orders: Law, Policy and Practice. In: Negotiated Justice and Corporate Crime. Crime Prevention and Security Management. Palgrave Pivot, Cham. https://doi.org/10.1007/978-3-319-78562-2_3

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