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The appellant, Leonard Gibson, was found guilty of the acquisition, possession or use of proceeds of criminal conduct contrary to s. 93B of the Criminal Justice Act 1988 (inserted by s. 30 of the Criminal Justice Act 1993), and sentenced to nine months' imprisonment suspended for two years. The relevant provisions of s. 93B of the Act are:

In preparing this report, the compliance sub‐group has set out to (a) summarise the current compliance regime as a matter of law and practice, (b) identify particular problem areas within that regime concerning public sector officials (PSOs), and (c) suggest recommendations for change. The result may be seen as providing features of a ‘model’ compliance structure designed to cause difficulties for corrupt PSOs seeking to launder the proceeds of their corruption; UK law and practice has formed the springboard for the model, but it should be stressed that in order to be of any utility any suggested changes would have to be adopted (effectively) universally throughout the financial world. Piecemeal adoption by one or a few states would merely be likely to drive the tainted monies elsewhere, and would not serve the desired purpose of reducing the extent/profitability of corruption.