On February 5, 2020, the Court of Appeal of England & Wales upheld an Unexplained Wealth Order (UWO) granted by the High Court against the wife of Jahangir Hajiyeva, an Azerbaijani banker jailed for defrauding the International Bank of Azerbaijan in 2016. Mrs. Hajiyeva was the first person to have been served with a UWO, a tool established in Chapter 1 of the Criminal Finances Act 2017 [3]. According to a press release [4] by the UK National Crime Agency (NCA), Hajiyeva v. National Crime Agency [5] involved a challenge to one of two UWOs granted against Mrs. Hajiyeva, which required her to explain how she and her husband could afford their home in Knightsbridge, London, with legitimately-acquired wealth. Mrs. Hajiyeva unsuccessfully appealed the UWO on four grounds: (1) "that the judge erred in his interpretation of the statutory test for identifying a politically exposed person"; (2) that the judge incorrectly determined that the International Bank of Azerbaijan was a "State-owned enterprise"; (3) that the judge incorrectly concluded that the requisite income conditions were met; and (4) that the judge erroneously held that the UWO does not violate spousal privilege or the right against self-incrimination. The NCA press release includes a comment by Sarah Pritchard, Director of the National Economic Crime Centre that the decision "is a significant result which is important in establishing [UWOs] as a powerful tool helping us to investigate illicit finance generated in, or flowing through, the UK." The decision may still be appealed to the UK Supreme Court.