Tokens: In
its
assessment
,
the
Court
confirmed
its
case
-
law
stemming
from
previous
Chamber
judgments
on
such
matters
,
in
particular
Sud
Fondi
v
Italy
[
3
]
and
Varvara
v.
Italy
.[4
]
It
thus
reiterated
that
the
confiscation
measure
imposed
by
the
Italian
authorities
constituted
a
“
penalty
”
within
the
meaning
of
Article
7
.
It
took
the
following
factors
into
account
:
that
the
illegality
of
the
acts
had
been
established
by
the
criminal
courts
;
that
the
sanction
was
related
to
a
criminal
offence
;
that
it
had
a
deterrent
effect
;
that
it
was
classified
as
a
criminal
sanction
under
domestic
law
;
and
lastly
that
it
was
particularly
severe
.
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