GOGITIDZE AND OTHERS v. GEORGIA JUDGMENT 27 that the use of the property in question did not procure advantage for the applicants to the detriment of the community (compare also with Phillips v. the United Kingdom, no. 41087/98, § 52, ECHR 2001-VII). (iii) Proportionality of the interference 104. As regards the requisite balance to be struck between the means employed for forfeiture of the applicants’ assets and the above-mentioned general interest in combatting corruption in the public service, the Court notes that the tenor of the applicants’ submissions in this respect was limited to calling into question the two major constituent elements of the civil proceedings in rem. They considered it to be unreasonable (i) that the domestic law allowed for confiscation of their property as having been wrongfully acquired and/or being unexplained, without the first applicant’s guilt on corruption charges having first been proved and (ii) that the burden of proof in the associated proceedings had been shifted onto them. (α) Whether the procedure for forfeiture of property was arbitrary 105. Having regard to such international legal mechanisms as the 2005 United Nations Convention against Corruption, the Financial Action Task Force’s (FATF) Recommendations and the two relevant Council of Europe Conventions of 1990 and 2005 concerning confiscation of the proceeds of crime (ETS No. 141 and ETS No. 198) (see paragraphs 55-65 above), the Court observes that common European and even universal legal standards can be said to exist which encourage, firstly, the confiscation of property linked to serious criminal offences such as corruption, money laundering, drug offences and so on, without the prior existence of a criminal conviction. Secondly, the onus of proving the lawful origin of the property presumed to have been wrongfully acquired may legitimately be shifted onto the respondents in such non-criminal proceedings for confiscation, including civil proceedings in rem. Thirdly, confiscation measures may be applied not only to the direct proceeds of crime but also to property, including any incomes and other indirect benefits, obtained by converting or transforming the direct proceeds of crime or intermingling them with other, possibly lawful, assets. Finally, confiscation measures may be applied not only to persons directly suspected of criminal offences but also to any third parties which hold ownership rights without the requisite bona fide with a view to disguising their wrongful role in amassing the wealth in question. 106. It was on the basis of those internationally acclaimed standards for combatting serious offences which entail unjust enrichment that the Council of Europe Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (MONEYVAL), Group of States Against Corruption (GRECO) and the OECD’s Anti-Corruption Network for Transition Economies, noticing the alarming levels of corruption in the country at all levels, repeatedly advised the