In order to be granted a freezing order, restraining the disposal of a defendant’s assets with the effect that an actual or anticipated judgment the applicant obtains against the defendant is likely to be rendered unenforceable, the applicant must satisfy the court that there is a real risk that this will happen unless the freezing order is granted.1 In a previous issue of this journal the kind of asset disposal which a freezing order may restrain was considered.2 This kind of disposal was described by Gloster LJ in Holyoak v Candy 3 as “unjustifiable dissipation”. The use of a defendant’s assets for ordinary living expenses or to pay legitimate business debts may well make the applicant’s task in enforcing judgment considerably more difficult, but this form of relief is not designed to put the applicant into a position better than that of other creditors seeking payment from the defendant. This current note considers the logically next question, of how great a risk of dissipation must the applicant show, on the assumption that the disposal of assets the applicant fears will occur constitutes dissipation. This question received careful and helpful elucidation in the judgment of Andrews LJ in Les Ambassadeurs Club Ltd v Songbo Yu.4 In some cases there will be overlap between the two questions, the evidence pointing towards the risk of disposal also throwing light on the question whether this is dissipation.