Criteria for Comparison

Crime-related Theory

Unexplained Wealth Theory

Shall the object of confiscation be the whole property whose legality is not proven (except for non-confiscable items) rather than only property originating from crime?

NO

YES

Do the authorities carry the burden of proof; do they need to establish a link between the property to be confiscated and the committed crime?

YES

NO

Is it appropriate to install a separate confiscation

procedure, apart from the corresponding criminal proceedings?

NO

YES