Where an offender is involved in two distinct criminal enterprises, the sentencing judge must structure sentences (including partial cumulation) to reflect the total criminality of both enterprises; it is an error to subsume the criminality of one enterprise entirely within the sentence for another by making all sentences concurrent. The amount of counterfeit currency produced is only one factor in assessing criminality, and the offence of making counterfeit notes is generally more serious than uttering or disposing of them. There is no established sentencing range or tariff for counterfeiting offences under the Crimes (Currency) Act 1981 (Cth).
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