[251] We submit that, if the tribunal of fact accepts the evidence of the witnesses that they provided the proceeds from these cheques to Mr Elliott, the issues left for the court's consideration are: Whether or not the monies in Mr Elliott's accounts constitute criminal property, whether in whole or in part?

[252] The Crown submits that the court, in considering the above questions and whether the properties constitute Mr Elliott's benefit from his criminal conduct, may draw reasonable inferences from the following circumstances:

[253] The evidence shows that between 2013 and June 2016, large deposits of cash were consistently made to Mr Elliott's accounts totalling $48,792,130, which was spread across mainly four savings accounts held by him.

[257] We submit that tables 9-12 reveal the following indicators from which the court can infer that the monies deposited to the accounts therein were the benefits from Mr Elliott's criminal conduct, thus constituting criminal property for the following reasons:

1.

It is also observed that the deposits are spread across Mr Elliott's accounts utilising the same pattern, frequency and amounts.

[259] We submit that the circumstances described by the witnesses who have testified that Mr Elliott gave them cheques to encash for work they had not done, then return the proceeds to him, have all provided the answer to make the court feel sure that Mr Elliott was engaged in obtaining money by false pretence or an act of corruption or some other unlawful conduct and thereafter depositing the criminal property.