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Emilija Berzanskaite
Emilija Berzanskaite
22nd October 2021
Internal Market Justice & Litigation

Analysis: “The Scope and Limits of Extended Confiscation of Proceeds of Crime in Non-Transnational Cases” by Francesco Rossi


On 21 October 2021, the Court of Justice delivered its first-ever judgment on confiscation of proceeds of crime since the adoption of the Freezing and Confiscation Directive (Directive 2014/42, hereinafter the Directive) in Okrazhna prokuratura – Varna (Joined Cases C‑845/19 and C‑863/19). In the case at hand, the Public Prosecutor handling the case in Bulgaria issued a request to confiscate approximately 2,200 euros for the first defendant (DR) and 4,800 euros for the second one (TS) as the purported gains of national drug trafficking, notwithstanding that both have been convicted for the different crime of possession of drugs for the purpose of their trafficking.

Therefore, in Okrazhna prokuratura – Varna, (e


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