On 23 March 2026, Mrs Justice O’Farrell handed down judgment in R (on the application of Ahmad) v Chief Constable of West Yorkshire Police [2026] EWHC 684 (Admin). Olivia Checa-Dover, leading Daniel Penman, successfully defended the grant of five search warrants and prior authority pursuant to s.47G POCA by a judge at Leeds Crown Court, which had led to the seizure of over £2 million in Bitcoin, as well as a large volume of evidence in an ongoing money laundering investigation.
The judgment can be accessed here.
The key points arising in this case were:
1. That even where a judge gives no reasons for the granting of an application beyond the signing of the form, where from the material before the court “the Judge can reasonably be taken to have been satisfied that the information in the application was sufficient to support the various statutory criteria addressed in the form”, the warrant can nonetheless be lawful. In this case, Mrs Justice O’Farrell found that the application contained a “comprehensive explanation of the investigation” and that the application had been “properly, accurately, and fairly presented in a balanced manner"
2. A reinforcement of the principle that warrants must be capable of being understood as self-contained documents, on a fair and proper reading and in the context of the investigation to which the warrants related. In this case, the warrants were held to be sufficiently clear and precise to be capable of determination without reference to any other document.
3. That there is no overlap between:
a. a warrant granted pursuant to s.352 POCA which authorises the search for and seizure of physical assets relating to money laundering, including unhosted cryptocurrency wallets; and
b. prior authority granted pursuant to s.47G POCA which authorises the search for and seizure of intangible cryptocurrency and “cryptoasset- related items”, both having been seized in the course of the investigation pursuant to the warrants and s.47C POCA respectively.
As cryptocurrency becomes more common in money laundering investigations, these issues will arise more frequently, and the importance of experienced and well- trained Financial Investigators preparing and presenting detailed, balanced, and accurate applications will only grow. Likewise, the accurate wording of warrants and other orders is only becoming more critical in this sensitive area.
For advice or training, please contact the clerks on clerks@kbwchambers.com or 01132 971 200.