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

This application is properly made under section 245A(3) of POCA 2002. The Applicant’s submission that notice may have prejudiced their ability to obtain a recovery order is plainly correct in the circumstances. The investigation is currently covert, but the Respondents will become aware of it in August 2025 when a VAT assessment is served.

The Respondents’ clear and longstanding links to China, as evidenced by regular large transfers from that country since at least 2010, are a significant factor. Their historical activity demonstrates a sophisticated ability to move large amounts of money quickly across various jurisdictions and through different mechanisms. This expertise, gained over the past 15 years, raises a real and immediate concern that they could liquidate or transfer their assets rapidly if they had been made aware of the freezing application.

As established in Jennings and reaffirmed in Younis, in cases involving allegations of dishonesty or, as here, money laundering, there is generally an inherent risk of asset dissipation given the very nature of such activities. The potential for assets to be moved to China, given the extensive financial ties to that country, underscores the urgency and necessity of a without notice order to preserve the assets for potential civil recovery. I am satisfied that there is a real risk of dissipation in all the circumstances.