Over the last two decades in particular, national legislatures have passed legislation aimed at ensuring that criminals do not profit from crime. This has been in response to the rise of organised crime and to the massive amounts of money being generated, in particular, by drug trafficking. It has been an attempt to destroy ‘the heart of the monster, its financial base’. This paper seeks to demonstrate that the proceeds of crime response by national governments can be perceived as evolving through a series of different models, thus allowing a comparative approach amongst different jurisdictions. Each model is composed of elements from three different strands: money‐laundering legislation, confiscation legislation and organisational structures and arrangements. These strands have each gone through their own evolution, which will now be examined.
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