The Court of Appeal, in R v Pace and another considered the mens rea necessary for the criminal offence of attempting to commit a money laundering offence under section 327 of the Proceeds of Crime Act 2002. The Court of Appeal, Criminal Division, in allowing the appeal, held that the judge had erred. The intent to commit a money laundering related offence involved an intent to convert criminal property and that connoted an intent that the property should be criminal property. As such, simple proof of only the mens rea element of suspicion was deemed to be insufficient.

View Pace & Anor v R. [2014] EWCA Crim 186, 18 February 2014