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

Having considered the detailed background, the relevant statutory provisions, and the applicable caselaw, I conclude that the Applicant has established a good arguable case that the three properties and the balance of the HBOS savings account are recoverable property, obtained through unlawful conduct. The overwhelming financial evidence showing large sums of money being available to the Respondents, which starkly contrasts with the Respondents’ declared income, together with measures designed to evade detection, strongly supports the inference of money laundering and unregistered MSB activities.

Furthermore, I am satisfied that there is a real risk of dissipation of these assets if the Respondents were to be given notice of this application, given their history of substantial, unexplained money movements and their international links.

It is proportionate and necessary for a Property Freezing Order to be granted at this stage to ensure that the assets are maintained while the civil recovery investigation proceeds. I have set a short return date which will give the Respondents the opportunity to be heard. The Applicant will, of course, continue to monitor the situation and will seek the discharge of the PFO if a good arguable case can no longer be made out.

Accordingly, the Property Freezing Order is hereby granted.