Law360, Expert analysis: On 28 July 2026, the Criminal Division of the Court of Appeal of England and Wales handed down judgment in R v Osmond, the first appellate decision on the tipping off offence contained within section 333A(3) of the Proceeds of Crime Act 2002 (POCA 2002). According to the analysis, with expert contributions from Andrew Reeves, partner and Global co-head of Investigations, Stuart Neely, partner, Emily Smith, senior associate and Ewan-Nize Gerber, associate, all at Norton Rose Fulbright LLP, the landmark decision clarifies that the tipping off offence may apply to disclosure of a specific, non-public investigative strand even where the wider investigation is publicly known, that the capacity in which information is received matters more than its source and that likely, rather than actual, prejudice is sufficient. It also confirms that the discretionary nature of an authority’s investigative power is not a defence to forgery where a false document is supplied to investigators.