Is your pizza criminal property?

A recent legal interpretation by the UK Court of Appeal has drawn surprising links between modern slavery in global supply chains and potential consumer liability for money laundering under the Proceeds of Crime Act 2002 (POCA). The ruling extends criminal risk to individuals who knowingly purchase products derived from forced labour, sparking widespread legal and ethical concerns.

John Binns, a partner at BCL Solicitors, highlighted the startling implications using the example of tomato purée sold in UK supermarkets. These purées, reportedly sourced from tomatoes harvested under forced Uyghur labour in China, could make consumers unwittingly liable for money laundering offences.

“If you use tomato purée to make your pizza toppings at home, you are now on notice that your meal may represent (in part) the proceeds of modern slavery,” said Binns. “This makes you guilty of money laundering, an offence that could carry up to 14 years in prison.”

Previously, the law focused on the proceeds of the original crime rather than the product itself, offering a defence to buyers acting in good faith. However, the recent ruling extends criminal taint to both the money and the product at every transaction stage. While acquisition and possession remain defensible, subsequent acts such as transferring or converting—like making a pizza topping—are potentially illegal.

Broader Implications

The decision has placed companies with high-risk supply chains in a legal grey area. They must now grapple with whether "suspicion" of criminality—a low evidentiary threshold—requires them to seek consent from the National Crime Agency (NCA) before proceeding. The ruling has also prompted debates among lawyers representing criminal suspects and highlighted the urgency of clearer guidance to make the law practicable.

For consumers, the implications are unsettling. The judgment doesn’t clarify whether liability applies to goods purchased before they were aware of supply chain issues, leaving even boycotts uncertain as a defence.

Binns advises cautious consumers to request consent via the NCA website if they suspect the origins of products they own or use, though he acknowledges this is a burdensome solution.

A Broader Debate

“This judgment raises serious questions about how we tackle modern slavery in supply chains and whether money laundering laws are the right tool for the job,” Binns concluded.

While the legal risks to individual consumers remain minimal in practice, the ruling underscores the need for systemic solutions to address modern slavery at its source rather than relying on consumers and businesses to navigate murky legal waters.

Copyright & permissions