Money laundering offences under Division 400 involving structured transactions over extended periods warrant starting points significantly higher than those previously imposed. For s 400.3(1) offences involving $3 million over 335 transactions, the starting point should be at least 11 years (range 12-14 years). For s 400.4(1) offences involving $556,400 over 59 transactions, the starting point should be at least 8 years (range 9-11 years). Sentences for FTR Act structuring offences are not a useful guide for Division 400 money laundering offences. Cumulative discounts of 54 per cent for plea and assistance are unjustified, and a separate quantifiable discount for contrition is erroneous.
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