Hughes, R. v

Factual and Procedural Background

On 4 December 2025, the Appellant pleaded guilty in the Crown Court at The City to nine counts of concealing, disguising, converting or transferring criminal property, contrary to section 327(1) of the Proceeds of Crime Act 2002. He was sentenced to six years’ imprisonment on 27 March 2026 and appealed against sentence with permission. [1][2][3]

The offending arose from the Appellant’s role in banking for an organised criminal group involved in substantial Class A and Class B drug dealing. Between 30 March and 7 May 2020, he collected, counted, stored, distributed and recorded cash exceeding £1 million, together with €124,850. [4][5][6][7]

Following his arrest in December 2020, £2,000 was found at his home. He made a prepared statement asserting limited involvement and thereafter declined to comment. He had two previous convictions from the 1980s. [8][9][10]

At sentencing, the judge treated the offending as category 3 harm and category A culpability. The judge concluded that it facilitated commercial-scale drug dealing and imposed concurrent six-year sentences after applying a one-third reduction for the guilty plea. [11][12][13][14][15][16]

Legal Issues Presented

1. Whether the offending was wrongly categorised as category A culpability. [17][18][19]
2. Whether the judge’s upward adjustment for the underlying drug offending was illegitimate or excessive and insufficiently reasoned. [20]
3. Whether the judge failed adequately to explain the effect of personal mitigation, particularly delay in bringing the Appellant to court. [21]
4. Whether the sentence was manifestly excessive or wrong in principle. [22]

Arguments of the Parties

Appellant’s Arguments

• The offending was unsophisticated, and the Appellant acted under the direction of persons higher in the organisation. His role was said to be significant rather than category A, and the category A features in the relevant guidelines were said not to exist. [17][18]
• The operations consisted only of physical cash collection, storage and couriering, and were not complex. [18]
• The upward adjustment by reference to the underlying drug offending was said to be illegitimate and excessive, and the judge was said to have failed to give proper reasons for the two-year uplift. [20]
• The judge was said not to have explained how personal mitigation, particularly the delay in bringing the case to court, affected the sentence. [21]

Prosecution Position

• The prosecution contended that the offending fell within category A culpability. [11]
• The prosecution’s sentencing note indicated that, under the drug offences guidelines, a significant role would have carried a ten-year starting point and a nine-to-twelve-year range before any further uplift for the most serious commercial-scale offending. [23]

Table of Precedents Cited

No precedents were cited in the provided opinion.

Court's Reasoning and Analysis

The Court of Appeal rejected the challenge to the category A classification. It accepted the sentencing judge’s assessment that the Appellant operated a carefully coordinated banking system for disposing of and recirculating criminal cash through tokens and covert communications. His use of counting machinery, maintenance of detailed records, and handling of substantial sums demonstrated sophistication, planning and a key, trusted role rather than that of a mere pawn. [24][19]

The Court held that the Appellant’s characterisation as having a significant role under the drug offences guidelines did not assist him. Even on that basis, the applicable starting point would have been ten years, with a nine-to-twelve-year range, before accounting for the substantial uplift associated with the commercial scale of the operation. [23]

The comparison with the drug offences guidelines and the sentences imposed on the Co-defendants supported the judge’s conclusion that an uplift was appropriate to reflect the serious drug offending facilitated by the money laundering. [25]

The Court also rejected the mitigation argument. Having reviewed the sentencing remarks, it concluded that the judge had been aware of and had taken account of the delay, the absence of further offending after arrest, and the Appellant’s personal mitigation. The judge had expressly referred to delay, and no additional explanation was required. [26]

Holding and Implications

Appeal dismissed. The sentence was neither manifestly excessive nor wrong in principle. [22][27]

The direct consequence was that the six-year concurrent sentences remained in force. The opinion identifies no broader implication or new precedent beyond applying the relevant sentencing guidelines to the particular facts. [16][27]