INTRODUCTION
This chapter applies the principle of minimization of ham' to the response of the criminal justice system to drug trafficking. Four alternative directions for the future of drug control are discussed:escalating penalties for trafficking; Decriminalization of possession for personal use while maintaining severe penalties for trafficking; full legalization of drug markets; and reduction in penalties for trafficking. The escalation in penalties, up to and including life imprisonment and in some countries death, is described as being more effective in expressing disapproval than in restraining trafficking. Tendencies towards decriminalization of possession for personal use are noted as being perfectly compatible with severe yet ineffective measures against traffickers. Legalization proposals are criticized as confusing the principle of a legal ban on trafficking with the way in which that ban is currently put into practice; also legalization is questioned on grounds of the development implications for 'producer countries'.

On balance, the best way to minimize negative outcomes, including drug market-related harm, is by continuing a ban on. trafficking but with a switch of resources within the criminal justice system, from incarceration to investigation. There is a need to distinguish and distance harm minimization proposals from proposals for legalization.

1 THE PATH OF RIGHTEOUSNESS

The first and most obvious path for the future development of drug control, illustrated most clearly by the United States, would involve focusing in particular upon drug use associated with minority groups, and a rapid escalation in penalties for trafficking offences. The two points, about race and punishment, go together. As Helmer convincingly showed in a Drug Abuse Council-funded study, it is historically at times of labour surplus within the United States, as poor Whites have been forced to compete more fiercely with ethnic minorities for the jobs available, that the drugs associated with those minorities (in reality or, more importandy, in the popular imagination) have become a focus for increased control (Helmer, 1975). That is to say, the minorities themselves have become a focus for increased controls, via drug control.

During the 1980s, it has been cocaine use and cocaine dealing among young Black males that have taken up the historic role of providing reason for enhanced policing of populations facing economic blight. Of course, such a policy response is also articulated in other ways, for example through the promotion of terminology such as 'mugging' in the 1970s (translation — street crime is Black-on-White) and 'wilding' in the 1980s (translation — vicious and sexual assaults are the responsibility of Blacks, not of Whites). But it is in the area of drug policy that the vision of the WASP (White Anglo-Saxon Protestant) has been most eloquently articulated:

The drug crisis is a crisis of authority — in every sense of the term 'authority'. What can be done to combat this crisis of authority? Two words sum up my entire approach: consequences and confrontation. Those who use, sell and traffick in drugs must be confronted, and they must suffer the consequences. By consequences, I mean that those who transgress must make amends for their transgressions. Consequences come in many forms. In terms of law enforcement, they include policies such as seizure of assets, stiffer prison sentences, revocation of bail rights, and the death penalty for drug kingpins. On these points I find general agreement...

We need to do more. We need to reconstitute authority. What those of us in Washington, in the states, and in the localities can do is to exert the political authority necessary to make a sustained commitment to the drug war. We must build more prisons. There must be more jails...
(Bennett, 1989: 4)

Quite so. You know it makes sense. We really must build more jails! And who are we going to put in these facilities? Everybody appreciates that ethnic minorities are over-represented in the prison systems of most developed countries, and also that drug trafficking throughout the 1980s provided the most dynamic motor of incarceration. For the United States, the Assistant Comptroller General reported to the House of Representatives in 1989 that

the rapid increase in federal prison populations is largely driven by the increase in the number of drug violators who are being incarcerated. Whereas the population of drug offenders increased by 31 per cent in the two years from September 1986 to September 1988, there was only a 5 per cent increase for all other offenders combined. Another measure of the relative effect of [the incarceration of] drug offenders is that they account for 79 per cent of the total increase among those sentenced to prison over that two year period.
(Chelimsky, 1989)

The report makes it clear that it is US drug control policy that is primarily responsible for the increase in incarceration.

The relationship between sentence length and the extent of prison overcrowding is direct. For example, if the increasing number of drug offenders were disproportionately sentenced to short sentences (less than one year), then the growth in prison population might be short-lived. lf, however, the majority of new [drug] offenders were being sentenced to longer stays in prison, the prison population could be expected to grow.
(Ibid: 13)

A similar, if in some respects less extreme, state of affairs obtains in many other countries. In Britain, for example, drug trafficking is one or the few crimes for which penalties rose sharply in the 1980s Porn et al., 1991: ch. 10), as the judiciary followed the dominant social sentiment to apply higher sentences and as legislation changed in the mid-1980s: maximum penalties of life imprisonment (and possible fine) plus asset confiscation replaced a maximum of fourteen years (and possible fines). Even in Holland, widely regarded as 'liberal' in its drug policies, prison sentences for trafficking offences are high relative to the tanff for most other offences, and so an increasing proportion of the prison population is made up of traffickers, many of them couriers and of foreign nationality.

2 THE PATH OF HOLLANDIZATION

The second path, illustrated in differing ways by British, Dutch and other European drug control policies, involves an attempt to reconcile increasingly heavy penalties for trafficking with some harm reduction for users. It is particularly the Dutch who represent this approach at the level of policy rhetoric, and for this reason the term 'Hollandization' is being heard on the European conference circuit, although the path they follow is shared with others.

Broadly spealcing, this policy amounts to a de facto partial decriminali-zation of cannabis possession (and, in restricted circumstances, retail sale of cannabis), with an emphasis upon health measures (treatment and syringe exchange, in particular) in preference to a purely crime control perspective on other drugs. In the Netherlands itself, the policy on cannabis extends from a toleration of possession and retail sale to a broader concept of 'market separation', where the aim is to keep markets in cannabis separate from markets in substances with 'an unacceptable risk'. This aspect is not favoured in most other countries, but police officers in parts of Britain take the view that cannabis trafficking is beyond their effective control. This does not mean that they do not attempt to police cannabis (indeed the greater proportion of criminal justice-generated drug statistics relate to cannabis) but it does reflect a practical police view on the need to focus primarily on other, less widely spread but more dangerous drugs.

As far as the Dutch emphasis on health policy rather than crime control is concerned, it can be said that such a policy is, to varying degrees, also shared by other European countries (and not by the United States). Even in Germany, sometimes taken in contrast to the Netherlands, health policy plays a part. In the southern European countries, there are pressures for decriminalization of personal possession and use in Italy, a well-developed response to HIV in Spain and France, and although resource difficulties restrict the Greek approach, health concerns are well to the fore there in terms of policy formulation. Most of the ex-communist countries are in movement from a denial of drug problems, through control responses sometimes involving psychiatry in a repressive mode, towards community-based and social responses to users. To find a European country that remains firmly against any hint of tolerance to drug users, we have to go to Norway.

To summarize on decriminalization, we can say that although it is seldom legislated, it is informally practised by many countries, if only partially and for practical reasons. Why not, some say, push harder in titis direction, and link public health and civil liberties issues in a coalition for legalization of the trade in all drugs currently proscribed?

3 THE PATH OF THE FREE MARKETEERS

The third path is that proposed by the advocates of legalization of the trades in drugs such as heroin and cocaine.

There seem to be three perspectives that are commonly taken on the likely consequences oflegalization of drug trades. 'These are: (a) perspectives on the potential impact on levels of consumption; (b) perspectives on the impact upon various indices of harm; and (c) perspectives upon the consequences for those developing countries within which psychoactive plants such as the opium poppy, coca bush and marijuana are grown.

Of course, we are all familiar with (a), the arguments about the possible impact of legalization upon levels of consumption. It is quite cornmon for government spokespersons to predict that legalization would result in an 'explosion' in drug use. Legalizers deny this, saying that drug consumption would probably remain at about the same level or perhaps fall. Who is right is probably one of those many questions which are context-dependent. Legalization in a situation of hitherto quite tight policing would probably have different (greater) impact upon availability than legalization in a situation of hitherto de facto loose control.

Perspective (b) is a bit more subtle, since it refers to levels of market-related and user-related harm and suggests that these would be reduced by legalization. For example, a legal market might mean less corruption of banking systems, enforcement agencies and government officials; legal consumption would mean few arrests, and so on. This is a very interesting argument that deserves to be articulated more clearly, but it does have a major problem. Advocates of legalization sometimes have a tendency to talk as if the various negative side effects of the present set of controls in the USA or elsewhere are inevitable consequences of any system of crirninalization, yet that is obviously not the case. Clearly, a country's legal system can proscribe trafficking without having maximum penalties as high as they are today (as described above, up to life imprisonment plus asset confiscation in many developed countries, death penalty in some other countries, particularly in South East Asia).

Twenty years ago, penalties were nothing like what they are today. At the end of this chapter I shall return to this point, suggesting a radical reduction in penalties for trafficking as a cost-effective approach to minimizing market-related harm, but within a dear commitment to continuing proscription of trafficking. But here let us simply register that there is a distinction between support for the ptindp/e of legal ban, and support for any specific penalty. Supporters of legalization seem all too easily to gloss over this distinction.

Let us turn now to perspective (c), which asks about the probable impact upon plant drug producing countries of a free market in the production of drugs. Here, we have to enquire into the present social and economic conditions of production of psychoactive plants and consider the likely future scenario under legalization.

At present, most psychotropic plant production is carried out by peasants and small tenant farmers who grow these crops on a proportion of the village lands as a‘ cash crop, the remainder being given over to food crops for familial consumption and/or local sale. Although, as has often been observed, the farmgate price is low in comparison with the prices at higher levels of the market, and minuscule compared with the price of the finished product as purchased by consumers, nevertheless the farmgate price is sufficient to provide farmers with cash that they would otherwise find difficult to raise.

Indeed this is one of the difficulties facing crop substitution programmes. The standard problem with such programmes is that the prices offered to farmers for the 'substitute' crops (wheat, fruits, tobacco, etc.) are generally not sufficient to offset the loss of income entailed in giving up psychotropics crops, especially when the farmer has to purchase special seeds, fertilizers, transport, or storage — expensive 'inputs' that were not required by the previous pattern of cultivation. It is not surprising that farmers who agree to take part in crop substitution programmes may show resistance to their full implementation as the implications emerge. It is widely recognized that, although crop substitution programmes may succeed on a local basis if sufficient outside funding is poured in and if enforcement is vigorous enough, these conditions cannot be achieved on a global basis. The best that can be achieved, for example, is the partial displacement of poppy cultivation from parts of Pakistan to less accessible Afghanistan, as happened in the 1980s; and a resurgence of cultivation in the Far East, as seems to be happening in the early 1990s. The world is just too big and the authority of many states too fragile to overcome completely the economic motivation of cash cropping.

Thus, paradoxically, illegality guarantees this form of production and its relatively good returns.

The plantation solution

Let us now ask what would happen if cultivation were to be made legal. The obvious result would be that peasant cultivation would no longer constitute the main form of production. As an advocate of the free market 'solution' describes, competition occurs between existing and new producers.

In the production of drugs, natural and synthetic, there are no scarce factors such as special land, or patented technical information, which would hinder entry into the market. Quotas [restricting the market to existing players] would be difficult to enforce, and the power of Third World producers would be further reduced from producers of natural and synthetic drugs in consumer countries. It would be likely, therefore, that the legal drug industry would be competitive at the production stage.
(Stevenson, 1990: 661)

The entry into the market of big farming interests and multinational corporations — at present excluded by the legal sanctions which only geographically a.nd economically peripheral producers can evade — would transform the present situation. Consider the ways in which legal commodities such as tobacco, tea, cocoa and sugar are produced. Typically, cultivation takes place in large farming units, specializing in one such commodity only, and using labour hired by the week or month. This would become the general pattern of cultivation of psychoactive plants, if legalized.

The exact consequences would vary with the nature of the crop. In the case of cannabis, for example, labour needs are low, with little to be done before harvesting except some weeding, which could be done manually or mechanically. In the case of poppy, the extraction of the juice from seed heads is a process that might be difficult to mechanize, thus necessitating a large labour input for a few weeks only. Otherwise, all the labour that is required is weeding between the seedling plants. In the case of coca, labour is needed to harvest the leaves about four times a year, assuming that machinery capable of stripping the leaves mechanically would not be developed. Regardless of the crop, however, the lessons of history of production of licit commodities strongly suggests that legalization of production of plant drugs would see large-scale monoculture cropping expand at the expense of small-scale, mixed crop peasant production.

What would be the consequences? Seasonal, low wage and partly migrant labour would accelerate at the expense of settled self-employment. Economic dependency would deepen as self-sufficiency became further eroded. The combination of increased competition, a fall in the farmgate price, seasonal demand for wage labour and aggregation of lands into large units would, together, intensify odsting pressures on peasant small-holders — especially in those (corrunon) situations in which tenants would have difficulty in proving or defending a right of land-use against landowners and officials keen to help 'modernize' the countryside. This is hardly an attractive development path.

Better the present situation, which involves a slower process of eroding of local self-sufficiency, than the implementation of the plantation solution. Proposals for legalization of trade in psychoactive plants can only be justified by an indifference to, or romantic misreading of, the development implications.

4 HARM MINIMIZATION AND DRUG MARKETS

The fourth and final policy path to be discussed involves an application of the concept of harm reduction/minimization to the drug market as well as to the user. I want to suggest that reduction of maximum penalties for trafficking offences would help to reduce drug market-related harm such as violence, would improve information flows to the enforcement agencies and hence would improve levels of apprehension and deterrence. A switching of resources from prisons to policing would increase the overall cost effectiveness of the criminal justice system in drug control.

Let us review the historical record. Two decades ago in Britain, when drug dealing had only recendy been legislatively distinguished from drug possession and drug trafficking had yet to be described as such, a person found guilty of supplying or intending to supply a kilo of a drug such as heroin might go to jail for about two or three years. By the early 1980s, penalties were creeping upwards, and the same crime might attract a sentence of around five years. In 1984, the Hodgson Committee recommended asset confiscation (seizing the proceeds of crime) 'as an altemative to longer prison terms: already, there was concern about prison overcrowding, cost, and lack of rehabilitative value of escalatiiig imprisonment (Hodgson, 1984). In 1986 the Drug Trafficking Offences Act did bring in asset confiscation, but imprisonment showed no downtum. Quite the contrary: the judiciary chased prison sentences further up. This trend was legitimized by Parliament in its 1985 Controlled Drugs Penalties Act, which for the first time provided for maximum penalties of life imprisonment. Our trafficker caught with a kilo might now expect a sentence approaching ten years, plus asset confiscation. The intention of Hodgson, that asset confiscation should partially replace imprisonment, was forgotten in a blaze of `get tough' rhetoric.

Has the escalation of prison sentences had any impact upon the problem? Of course, this is difficult to tell for sure. But longer sentences evidently have not provided a level of deterrence sufficient to reduce the extent of trafficking, as evidenced by the iturease in trafficking in Britain, in Europe, and on a global level. This is hardly surprising from a criminological perspective, since it is the likelihood of being caught, rather than the penalty that one aims to escape, that is generally understood to provide deterrence. Heavy prison penalties may be symbolically important (see Moore and Kleiman's 1989 discussion of law enforcement measures as 'expressive' of social disapproval) but they are not effective in any other way and they cost a lot of money.

How, then, should we proceed? Perhaps we need to go back to general principles, and ask what it is that we are trying to achieve. The general principle behind anti-trafficking policy should be similar to the general principles behind policy on drug consumption. Such an approach would lead us to pursue measures congruent with (a) minimization of the extent of trafficicing and (b) minimization of the various forms of harm that are contingently associated with drug markets and control measures (cf ACMD, 1984; Pearson, this volume; Dom et al., 1991).

Harm minimization is a well-understood concept in relation to management of the drug user, whereby policies and practices are adjusted so as to minimize the extent to which users and those around them suffer in terms of health problems, social problems, legal problems and financial problems that may be contingently related to drug consumption but are not inherent in it. The best-known example the attempt to limit the spread of HIV by provision of sterile injecting equipment and injection advice, but the practice of harm minimization has developed along social, legal and financial dimensions as well as the more familiar health dimension. To take an example familiar to students of the early so-called 'British system' of prescribing injectable heroin, one of the aims of that system was to prevent or slow the emergence of an illicit market and hence keep users away from tile legal, social and financial harms that it might present. This policy had been all but abandoned by the early 1980s, but by the middle of the decade there was a resumption of short-term prescribing to lure people into contact with counselling facilities and syringe exchange schemes. In the field of criminal justice, the British police are increasingly giving formal warnings to minor drugs offenders rather than taking them to court, the aim being to minimize unnecessary criminalization. So, one way or another, the concept of harm minimization in relation to users is well understood, if patchily adopted.

How might harm minimization be understood in relation to drug markets? Of course, one way of reducing the various types of harm that may be associated with trafficicing, purchase and consumption is to hold down the market in quantitative terms: minimum market, minimum amounts of drugs, and minimum harm, other things being equal. But other things may not be equal, in the sense that certain strategies that look as if they reduce the market might actually make it nastier. Consider, for example, the US police practice of shooting at fleeing suspects who fail to stop when challenged. Might this not provoke suspects to carry weapons more frequently, whereupon they are more likely to use them again.st police and others in the market? We are fortunate in Europe that our enforcement agencies are less gun-happy than their US counterparts. Consider proposals for the death penalty for trafficking; might this not also motivate even more traffickers to take desperate steps to escape arrest?

Whatever powers are given to the police and to the courts, it is very clear that the illicit drug market will continue to exist to some extent. So, public policy has to be concerned with reducing — or, at the very least, not exacerbating — forms of harrn that are only contingently associated with the market. This should be the criterion against which all policy proposals be evaluated: to what extent would they tend to hold down the market in quantitative terms and minimize the harm (legal, social, financial, etc.) associated with it.

To take the British context, a halving of maximum prison sentences, returniqg us roughly to the 'tarifF of the 1970s, may be a useful proposal for the purposes of debate. It is time to consider reform of the Drug Penalties Offences Act. A halving of prison places currently taken up by trafficicing offenders would save millions. The fmancial resources thus freed would then allow considerable enhancement of policing, especially in respect of financial intelligence, precursor intelligence, surveillance operations and other means of investigation and case-building. The enhancement of these sophisticated elements of enforcement would result in a higher rate of apprehension of traffickers (though the increase would be modest, according to Wagstaff and Maynard, 1988), hence rather more deterrence, slightly less trafficking and, as a consequence, lowered availability of drugs. In other words, a re-allocation of resources from unproductive incarceration to modem forrns of investigation would go some way to meeting the first element of prevention — there would be a smaller drug market.

Another important bit of legislation that needs critical scrutiny is the Drug Trafficicing Offences Act (DTOA) of 1986. This Act made it obligatory for the courts to order a financial investigation of every person found guilty of a trafficking offence, so that an estimate of proceeds of trafficking could be made and an asset confiscation order made in the case of conviction. Of this requirement, Michael Zander has said

Drug trafficking conjures up the image of fabulous profits. But most drug trafficking offenders are probably fairly small time... This does not mean that the existing power of confiscation is unnecessary. But it does help to put into perspective the call for yet more draconian penalties. It may even raise the question whether the scarce expert skill of detection available to the police would not be better deployed in the more serious cases than in pursuing so many minor offenders. It may actually be more productive, in every sense, to restrict confiscation in drug trafficking cases (as under the Criminal Justice Act 1988) to those involving sums of more than k10,000.
(Zander, 1989: 52)

Yes, why not bring the DTOA into line with the 1988 Criminal Justice Bill, which in relation to crimes other than trafficking calls for confiscation of proceeds only above k10,000? This would bring anti-trafficking legislation into line with legislation on other areas of gainful crime. It would also release financial specialists, currently tied up with the implementation of confiscation orders in minor trafficking cases, to initiate new and more substantial investigations. Here, as elsewhere, a 'liberal' reform in relation to punishment could be a plank in a wore effective anti-trafficking strategy. Sadly, although the DTOA was due to be discussed in Parliamentary circles during 1991 and may eventually be reformed, the chances of change along the lines suggested by Zander are at best uncertain.

Radical reductions in prison sentences might well reduce other problems, too. First, the motivation to use violence to avoid arrest might be reduced, since it would hardly be worth risking a long sentence for a violent act if abstaining from violence and getting caught resulted in a relatively short sentence. This would be a worthwhile outcome in its own terms.

Furthermore, a reduction in the lengths of prison sentences facing traffickers might reduce their motivation to threaten or use violence against suspected informants. At present, the degree of intimidation induced by the desire to escape 'exemplary' sentences has so reduced the flow of high-quality leads from frightened informants that large rewards are being offered in an attempt to restore the situation. It is widely accepted in policing circles that the motivation of good informants is far more complicated than financial greed (Dom et al., 1991). There is the danger that big rewards will induce some traffickers to intervene more forcefully against potential informants. If we want to reduce the market-related harm of violence, then we need to reduce every incentive for the drug trade to be further 'hardened'. At the very least, we must avoid further escalations in penalty.

CONCLUSION: SOME OBSTACLES

The escalation in penalties for trafficking has coincided with worldwide expansion of the drug market and its transmutation into a nastier form than previously. The intensity of punishment threatened does not guarantee the effectiveness of deterrence. Rather the reverse may be the case. What, then, drives the punishment motive, if prevention does not?

Domestic policies are part of the answer, as I indicated at the beginning of this chapter. But we should also accord some role to foreign policy. If we look at the foreign policy of the US, in particular, we find that whenever this country has a problem with part of the developing world, drugs that come from that region become described as particularly dangerous, traffickers in them are targeted as particularly evil, and problems of the inner cities become blamed on consumption of those drugs. In the post-Second World War period, as the US attempted, unsuccessfully as it turned out, to take the place of the departing French in the Far East, so heroin traffickers became dramatized — ironically, since it seems that it was those 'friendly' to the US rather than its enemies that were most involved in that trade (McCoy, 1974). Later, a similar pattern emerged in the Afghanistan/ Pakistan region. As Latin America showed signs of independence, cocaine was re-positioned by US authorities, from being a relatively harmless drug to the worst drug imaginable.

It is interesting to speculate about the future, given the troubles that emerged in 1990 in the Middle East, one region for cultivation of psychoactive plants other than coca. If this region becomes even more of a sustained focus for US and European foreign policy, may we expect that cannabis will become re-described as possessing previously unrecognized dangers? Watch this space! Drug policy may for some time retain its characteristic of throwing up the most spectacular visions.

Such observations are not intended to imply that drug control policy is only an effect of broader foreign or domestic policies. We should not forget that the United States was prepared to 'lean on' Turkey to persuade that country to discontinue opium cultivation, even though such pressure was not especially desirable from a foreign policy point of view. Similarly, Mexico became the recipient of considerable pressure when that country supplied the bulk of US heroin. In these cases, it seems fair to describe drug policy as helping to shape foreign policy. But, having made these specific acicnowledgements, it does also appear that domestic circumstances and foreign policy quite often have large and complicated parts to play. We should not generally expect a discussion of drug policy per se always to be taken strictly on its merits.

In closing, I hope that I have managed to convey some of my dis-ease over the two main 'solutions' being touted for drug problems — heavier penalties and legalization. Heavier penalties can only make drug markets 'heavier'; indeed there is a case for reducing imprisonment and re-directing the money saved to the policing side. LegaLization of production and marketing will no doubt remain a pipe dream — which is a good thing, because it would provide a poor development path in regions of countries in which psychoactive plants are cuirently cultivated as a cash crop in conditions of peasant semi-self-sufficiency. It may seem a litde unheroic and uninspiring, but the best option may be the middle course of fine-tuning the criminal justice system through a general reduction in penalties for trafficking.

ACKNOWLEDGEMENTS

The author thanks Karim Murji, Pat O'Hare, Jasper Woodcock and Lorraine Olver for criticisms and suggestions on an earlier draft.

REFERENCES

Advisory Council on Misusc of Drugs (1984) Prevention, London: HMSO.

Bennett, J. (1989) 'Restoring authority', New Perspectives Quarterly 6 (2): 4-7.

Chelimsky, E. (1989) Assistant Comprollcr General, in the Introduction to US General Accounting Office, Federal Prisons: Trends on offender characteristics, Gaithersburg, Maryland: GAO.

Dom, N., Mutji, K. and South, N. (1991) Traffickers: Drug markets and law enforcement, London: Routicdgc.

Helmer, J. (1975) Drugs and Minority Oppression, Ncw York: Scabury.

Hodgson, D. (1984) The Profits of Crime and their Recovery, London: Heinemann.

McCoy, A. W. (1974) 'Thc politics of the poppy in Indochina: A comparative study of patron-client relations undcr French and Amcrican administrations', in L. Simmonds and A. Said (cds) Drugs, Politics and Diplomacy, Beverly Hills: Sage, pp. 112-36.

Moore, M. and Kleiman, M. (1989) The Police and Drugs, Washington, DC: National Institute ofJusticc.

Stevenson, R. (1990) 'Can markets copc with drugs?', The journal of Drug Issues 20 (4): 659-66.

Wagstaff, A. and Maynard, A. (1988) Economic Aspects of the Illicit Drug Market and Drug Enforcement Policies in the United Kingdom, Home Office Research Study 95, London: HMSO.

Zander, M. (1989) Confiscation and Foeiture Law: English and American Comparisons, London: Police Foundation.