A sentencing judge may take into account the extent to which an offender's failure to cooperate with investigators contributed to delay between offending and sentencing, and this may reduce the mitigating weight given to delay. The principle that the significance of delay does not depend on whether there is a satisfactory explanation does not preclude consideration of the offender's own contribution to the delay. A broad-brush approach to individual sentences is permissible where offending constitutes a single ongoing fraudulent enterprise, even where amounts appropriated differ significantly between counts.
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