A 1980 decision by the House of Lords in the United Kingdom ruled that the English criminal courts lacked the power to forfeit such profits even though earned by convicted defendants. The Howard League of Penal Reform, concerned that judges would impose longer prison sentences, established an independent committee to propose reforms and to look at models for confiscatory powers. Also of concern is the delicate balance between ensuring that crime does not pay and the commitment to due process before financial punishments are imposed. 2 references. (Author abstract modified)