PRIORITY

CYPHER CAT A

GRPS 290

FM FCO 141215Z

CONFIDENTIAL

LARI

CONFIDENTIAL

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REF.

12

(HK)

TO PRIORITY HONG KONG TELNO 172 OF 14 FEBRUARY 1974

1

MY TELNO $9 AND YOUR TELNO 139: PREVENTION OF BRIBERY ORDINANCE.

FROM STUART,

1. THE AMENDMENTS PROPOSED IN EXCO PAPER XCC(74)4 AS AMENDED BY

YOUR TEL. UNDER REFERENCE ARE ACCEPTABLE TO US AT OFFICIAL LEVEL. WE ASSUME THAT THE NEW 12(3) IS INTENDED TO REPLACE 12(3) AND 12(4)

IN THE ORIGINAL DRAFT CIRCULATED TO EXCO. WE ALSO TAKE IT THAT THE

INTENTION OF THE NEW 12(3) IS STILL TO PERMIT CONFISCATION OF THE

VALUE OF PROPERTY IN THE POSSESSION OF THIRD PARTIES, BUT BY MEANS OF ORDERS ENFORCEABLE ONLY AGAINST THE CONVICTED FERSON. THIS IS

BECAUSE THE NEW 19(2) PROVIDES THAT A CONVICTION UNDER 10 1(B)

CAN BE FOUNDED ON THIRD PARTY PROPERTY IN THE PRESCRIBED

CIRCUMSTANCES, AND THE NEW 12(3) APPEARS TO APPLY TO ALL THE PROPERTY WHICH CAN BE BROUGHT WITHIN 10 1(B) (ASSUMING THAT QUOTE ACQUISITION UNQUOTE ALSO MEANS QUOTE ACQUISITION OF CONTROL UNQUOTE).

2. IF THIS IS NOT SO AND IF YOU INTEND TO EXCLUDE NOT ONLY THE

PROPERTY OF THIRD PARTIES, BUT ALSO ALL PROPERTY IN THE POSSESSION OF THIRD PARTIES, FROM CONFISCATION ORDERS, THEN THE NEW 14(B)

WOULD APPEAR TO BE UNNECESSARY.

3. IF OUR FIRST ASSUMPTION IS CORRECT, THE AMENDMENT WOULD SEEM TO

BE LEGALLY RESPECTABLE, SINCE NO ORDER AGAINST A THIRD PARTY WOULD BE INVOLVED, BUT THERE MIGHT BE PRACTICAL DIFFICULTIES IN ENFORCING

THE JUDGMENT. A CONVICTED PERSON COULD PRESUMABLY CLAIM THAT

HE HAD NO CONTROL OVER THE FUNDS CONCERNED, ALLOW HIMSELF TO BE BANKRUPTED IN HONG KONG, AND THEN RETIRE ELSEWHERE TO SHARE IN THE

MONEY. WE TAKE IT, HOWEVER, THAT THE IMMEDIATE PRESENTATIONAL

POINT OF BEING SEEN TO TAKE WHAT ACTION IS POSSIBLE AGAINST ALL

THE FUNDS DEEMED IN THE CRIMINAL CASE TO HAVE BEEN RECEIVED CORRUPTLY, IS OVERRIDING IN HONG KONG.

CONFIDENTIAL

/. HOWEVER,

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