where receipt was not beneficial but in a ministerial capacity (e.g. as banker or solicitor) on behalf of a client to pass it on as directed by the client there can be no liability for knowing receipt if they pass it on, only for dishonest assistance (as alleged for the solicitor defendant in Twinsectra). If, however, an agent lawfully receives property but then deals with it for his own benefit knowing this to be inconsistent with the relevant fiduciary duty, he can be personally liable.