The key elements for assistance were made clear by Lewison J in Ultraframe (UK) Ltd v Fielding [2005] EWHC 1638 (Ch). The defendant does not need to know precisely the nature of the breach of fiduciary duty, so long as they have some appreciation that they are helping someone who is up to no good (at [1505-6]). If a defendant has somehow made the planning of the breach, the actual breach or the subsequent cover-up easier than it otherwise would have been, then the defendant has assisted. Acts that come within this notion of assistance should be widely interpreted. However, if the defendant’s actions have only taken place after the breach and subsequent cover-up have been fully implemented, then the defendant cannot have assisted in the breach at all.