AC-2025-LON-002199 - [2025] EWHC 2057 (Admin)

I conclude that the Applicant has presented a good arguable case that the four assets are recoverable property. The evidence adduced, primarily through Mr Woollard’s detailed financial analysis, clearly demonstrates a substantial discrepancy between the Respondents’ declared income and their actual financial activity and asset acquisition. Their combined average annual income after tax was approximately £17,130.46, yet their expenditure on ‘high-end’ prestige goods alone exceeded £1 million between 2010 and 2018. Furthermore, they have apparently ‘loaned’ £194,149 to their company, UKFRESHASIANFOOD Limited, by October 2023. This lifestyle and level of financial support for their business are simply not commensurate with their declared earnings.

The acquisition of three properties outright, without mortgages, despite their minimal declared PAYE income, further supports the Applicant’s case. The funding for these properties, as detailed by the Applicant, is strongly linked to significant monetary transfers and cash deposits from various third parties, often from China, that are not explained, on the material available, as deriving from any legitimate sources.

The pattern of numerous, often geographically dispersed, cash deposits (over £544,000 between 2010-2018), and a later shift to significant third-party monetary transfers (over £1.1 million between 2018-2024), points towards a deliberate strategy to move large sums of money in a manner designed to avoid scrutiny. The Applicant has submitted that the characteristics of these movements, are indicative of Daigou schemes, Chinese underground banking, and the operation of an unregistered MSB.

I am satisfied that, on the present material, the money laundering offences can be inferred from the way the funds have been dealt with. The scale, nature, and provenance of the monies coming into the Respondents’ accounts, coupled with their minimal declared income, strongly suggest that these funds are the proceeds of unlawful conduct. The Applicant’s submission that there is a “good prospect of the application for Civil Recovery succeeding” at trial, as articulated in Szepietowski, is well-founded.