Satisfaction of the requirement of ‘knowledge’ was described as ‘problematic’ by Nourse LJ in the Court of Appeal in Bank of Credit and Commerce International (Overseas) Ltd and another v Akindele [2000] 4 All ER 221. Therefore the court developed the current test: that a defendant will be personally liable for ‘knowing receipt’ where it would be ‘unconscionable’ for them not to be so liable, so that they can be liable when not dishonest, seemingly, in the sense of not having type (i), (ii) or (iii) knowledge. Since then the above cases dealing with type (iv) knowledge indicate that type (iv) knowledge will suffice for liability, but that negligent conduct of type (v) cannot give rise to liability. Nourse LJ deprecated use of the five technical types believing it easier to replace them by the ‘unconscionability’ test, despite the uncertainty that this causes.