When sentencing for multiple offences arising from a Ponzi scheme or ongoing fraudulent course of conduct, the Pearce sequence must be followed: an appropriate sentence must be fixed for each individual offence before considering cumulation, concurrence and totality. A 'broad-brush' approach permitting roughly proportional sentences across similar counts is available, but does not extend to first fixing the total effective sentence and working backwards. Setting out to impose a sentence in the 'toughest' category is an irrelevant consideration that may mask error.
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