Die Beweissituation im Recht der selbstständigen Einziehung in Deutschland und England

How to prove the illegal origin of assets is one of the most controversial issues of confiscation law. The state is faced with the problem as to how to deal with assets which have prima facie an illegal origin, but for which full proof of the criminal act and thus of the illegal origin cannot be provided. When introducing the non-conviction-based confiscation, Germany was guided by foreign legal systems, such as England and Wales. This book examines the evidential situation both under German and English law by way of a legal comparison.