28 GOGITIDZE AND OTHERS v. GEORGIA JUDGMENT Georgian authorities that they undertake legislative measures to ensure that the confiscation of proceeds, including value confiscations, applied mandatorily to all corruption and corruption-related offences and that confiscation from third parties should also be possible. The Court observes that the domestic authorities put the received instructions into practice by adopting the amendment of 13 February 2004. As far back as April and June 2006, and then again in September 2013, the above-mentioned international legal expert bodies commended the authorities for having largely complied with their instructions. They noted that, thanks to the introduction of civil proceedings in rem in addition to the possibility of confiscation through criminal proceedings, the Georgian legislation had been brought into line with the appropriate requirements of the international legislation, and in particular with the relevant Council of Europe Conventions, although they still warned the Georgian authorities against possible misuse of that procedure, calling for the utmost transparency in that regard (see paragraphs 66-73 above). Indeed, the Court considers it important to emphasise that those legislative measures considerably helped Georgia to move in the right direction in combating the corruption (see paragraph 73 above). 107. The Court also recalls previous cases in which it was required to examine, from the standpoint of the proportionality test of Article 1 of Protocol No. 1, broadly similar procedures for the forfeiture of property linked to the alleged commission of various serious offences entailing unjust enrichment. As regards property presumed to have been acquired either in full or in part with the proceeds of drug-trafficking offences or other illicit activities of mafia-type or criminal organisations, the Court did not see any problem in finding the confiscation measures to be proportionate even in the absence of a conviction establishing the guilt of the accused persons. The Court also found it legitimate for the relevant domestic authorities to issue confiscation orders on the basis of a preponderance of evidence which suggested that the respondents’ lawful incomes could not have sufficed for them to acquire the property in question. Indeed, whenever a confiscation order was the result of civil proceedings in rem which related to the proceeds of crime derived from serious offences, the Court did not require proof “beyond reasonable doubt” of the illicit origins of the property in such proceedings. Instead, proof on a balance of probabilities or a high probability of illicit origins, combined with the inability of the owner to prove the contrary, was found to suffice for the purposes of the proportionality test under Article 1 of Protocol No. 1. The domestic authorities were further given leeway under the Convention to apply confiscation measures not only to persons directly accused of offences but also to their family members and other close relatives who were presumed to possess and manage the ill-gotten property informally on behalf of the suspected offenders, or who otherwise lacked the necessary