Provisional attachment under the anti-money laundering framework...

Provisional attachment under the anti-money laundering framework was partly invalidated where the Tribunal found no foundational material to show that pre-existing commercial agreements were designed to layer later proceeds of crime or could be retrospectively treated as commercially irrational or inter-connected transactions under Section 23. Attachment based on the first and second transactions was therefore set aside. By contrast, the Tribunal accepted that a delayed payment linked to the dairy sale arrangement was not credibly explained as a later adjustment against other dealings, and sustained attachment to the equivalent value of that amount. The appeals were thus partly allowed, with attachment continuing only to the specified extent.